This is a review^[1] in the series ‘Members of Missions Interlink’, Missions Interlink being ‘the Australian network for global mission’^[2] (and a means for a Member to get income tax exemption when it might not otherwise be available^[3]. ‘Christian and Missionary Alliance of Australia’ is one such Member^[4].

The name in the membership list links to the website for ‘TheAlliance/The Christian and Missionary Alliance of Australia’. Here they seek donations from the public.

Donors

Given what Missions Interlink does, ‘Christian and Missionary Alliance of Australia is probably a charity.

The charity regulator, the ACNC, in their article, Donating to Legitimate Charities, gives “some things to consider to help you make sure your donation is going where it is intended”:

1. Check the charity’s name.
2. Ask for identification from anyone seeking a donation.
3. Be careful of online requests for donations.
4. No tax deduction doesn’t mean the charity is not a legitimate one, and
5. Find out more about how the charity says it uses donations.

Here’s the results for ‘TheAlliance/The Christian and Missionary Alliance of Australia’, with #5 supplemented by the essentials of the ACNC’s What should I consider when deciding which charity to support?^[5]

Question 1

A search on ‘TheAlliance’ gives no result. There’s still no business name registered; therefore there should be no trading under this name.

A search on ‘The Christian and Missionary Alliance of Australia’ gives an almost identical charity, The Christian and Missionary Alliance of Australia Inc. [The Alliance].

Again, there’s still no business name registered by The Alliance, so they should be including ‘Inc.’/’Incorporation’ on the end of the website name (and elsewhere).^[6]

Other registrations

• As an ACT incorporated association (A 02382).
• Still not registered for fundraising in two, possibly three, of the states that it operates in.
• Despite doing business interstate, it still doesn’t have the required registration (an ARBN).

Question 2

There is nothing on TheAlliances’ website to suggest that they use either volunteer or professional fundraisers door-to-door or in the street.

Question 3

The web address begins with a closed padlock symbol, so the website is secure [the ACNC article above]. There is nothing on the page where you enter your information about the security of that information. However, tithe.ly, provides the facility, so you should be safe.

Question 4

The Alliance’s ABN record (via their ACNC Register record) says that it is not entitled to receive tax-deductible gifts. The giving page supports this.

Question 5^[7]

Context

About the CM&A

Ministries

‘The Alliance Institute for Mission’, which is a charity, presents to the public as something separate to The Alliance^[8]. But it doesn’t even have an ABN. (It used to be a registered as a charity, but no longer is. Why?)

From previous reviews we know that there is more to The Alliance than is described via the above two links. There are six other registered charities, and two unregistered charities (that’s eight charities), which are controlled by The Alliance:

The Christian And Missionary Alliance Development Fund^[9]

• A registered charity.
• The directors are Kenneth Graham, Daniel Yeung, Ian Cullen, Michael Pomerenke, Roger Lang, and Wendy Jensen.
• There is no mention of this entity on the website.
• There is no mention of this entity in the Financial Report 2020 (see below).
• Its ACNC Register entry is unhelpful in merely describing the charity’s activities as ‘Religious Activity’. Its AIS 2020 is similarly unhelpful. Last year the AIS said “Assist the churches and ministries of the C&MA Australia with investment, loan, and building projects and other services related to C&MA charitable work.” Presumably this still applies.
• No Financial Report is required by the ACNC (‘Small” size). But although the revenue is less than $250K, the AIS 2020 shows that it had assets of $3.63 million and liabilities of $3.26 million.

The Christian And Missionary Alliance of Australasia Property Trust^[10]

• A registered charity.
• The directors are Brendon Fung, Kwong Lai, Matthew Hung, and Pui Lai.
• There is no mention of this entity on the website.
• There is no mention of this entity in the Financial Report 2020 (see below).
• Its ACNC Register describes its activities as ‘Properties were held in trust and administered on behalf of churches and entities of the Christian & Missionary Alliance of Australia’.
• Despite ‘Australasia’ in the title, the Register says that charity does not operate outside Australia.
• No Financial Report is required by the ACNC (‘Small” size). But although the revenue is less than $250K, the AIS 2020 shows that it had assets of $2.43 million and liabilities of $1.12 million.

The Trustee For CAMA Services Overseas Aid Fund

• A registered charity.
• The directors are Aman Gupta, Jennifer Fung, Kelvin Kam, Kenneth Graham, Kwan Ho Suen, Peter Laughlin, and Wan Yeung.
• There is no mention of this entity on the website.
• There is no mention of this entity in the Financial Report 2020 (see below).
• The Trustee has put no information on the Register (including via its AIS 2020) about what it does (and the ACNC has allowed this).
• The constitution is for an ACT incorporated association, Cama Services Overseas Aid Inc.  It established, and is the trustee of, the Fund.
• Both the Fund and the Trustee have ABNs, but the Fund is not a registered charity.
• No Financial Report is required by the ACNC (‘Small” size); its AIS 2020 shows zero for all figures. (This means that there is no financial information disclosed for the Fund.)

CAMA Services Overseas Aid Fund Inc

• See No. 3 above.
• Has an ABN but is not a registered charity.
• Yet it is listed on the public giving platform Good2Give.

Australian Chinese Alliance Churches Committee

• A registered charity.
• With its own website.
• Its constitution [ACNC Register] shows that it is a standing committee of The Alliance.
• But here is no mention of this entity on The Alliance’s website.
• And no mention of this entity in the Financial Report 2020 (see below).
• No Financial Report is required by the ACNC (‘Small” size), and because the Committee is a Basic Religious Charity (ACNC Act), no financial information is required in its AIS 2020.

The Southside International Trust

• A registered charity.
• The name, from the governing document is ‘The Antioch International Church Trust’. It was established to hold the church’s property.
• The trustee is the Property Trust (see No. 2 above).
  • The directors are the directors of the Property Trust (see above), plus Shirley Towner.
• Although the Trust has existed since 1995, The trustee (the Property Trust) only registered it as a charity in 2020. It has therefore not yet been required to submit an AIS.
• There is no mention of this entity on The Alliance’s website.
• Nor in their Financial Report 2020 (see below).
• The Trustee has put no information on the Register about what it does (and the ACNC has allowed this).

The Southside International Trust No. 2

• A registered charity.
• A trust settled in 2005 by one of the current directors of the charity in favour of ‘Southside International Church’.
• The trustee is the Property Trust (see No. 2 above).
  • The directors are the directors of the Property Trust (see above), plus Shirley Towner.
• Although the Trust has existed since 2005, it appears that the trustee only registered it as a charity in 2020. It has therefore not yet been required to submit an AIS.
• There is no mention of this entity on The Alliance’s website.
• Nor in their Financial Report 2020 (see below).
• The Trustee has put no information on the Register about what it does (and the ACNC has allowed this).

The Christian and Missionary Alliance Pastors Fund

• Has an ABN, is a charity, but is not registered as one.
• There is no mention of this entity on the website.
• There is no mention of this entity in the Financial Report 2020 (see below).

Then there’s Asia Pacific Alliance Churches

• Has its own website.
• Ken Graham, the President of The Alliance, is the Treasurer and one of the seven directors.
• Is it an Australian entity? No ABN.
• There is no mention of this entity on The Alliance’s website.
• There is no mention of this entity in the Financial Report 2020 (see below).

Financial Reporting

The account of how a charity uses donations is the Financial Report on the ACNC Register.

In this Report the committee of The Alliance made the following declaration:

For this to be true, the committee members must have chosen the correct type of financial statements:

These directors said that The Alliance was not a reporting entity:

As you can see, this was their justification for producing the lower-standard special purpose financial statements.

But this is only the correct choice if there are no users who are dependent on a regulator to specify the form of the financial statements. If users are not able to ring up The Alliance’s office and command the preparation of reports tailored to their needs, then they are users who are dependent on the regulator. And the other kind of reports, general purpose, are the ones that must be produced.

With professional management, 81 congregations across six states, missionaries in many overseas countries, 15 employees, and a property portfolio, the committee’s choice is ridiculous. They have therefore made a false declaration^[11].

Preparing special purpose reports means that charities do not need, among other things, to consolidate (produce a combined picture if they control over entities), and do not need to disclose related parties and transactions with related parties.

This means that the Financial Report 2020 is a report of the activities of The Alliance only, without those of the Institute, the Property Fund, the Development Fund, CAMA and the other charities. And without those other disclosures required by the regulator for general purpose reports. Not a true and fair view.

Who was responsible?

The Committee Members’ Report (Financial Report 2020) tells us that these were the people who were responsible for the above decision:

Ken Graham

Dr Peter Laughlin

Patrick Suen

Aman Gupta

Daniel Yeung

Simon Russell-Brown

Kelvin Kam

Nelson Koh

Jennifer Fung^[12]

The ACNC Register shows that there have been no changes since.

The use of your donations

If you are still willing to consider donating to The Alliance, here is how your donations were used:

Cash spent

From the Statement of Cash Flows (with last year in the second column):

No further information is given on this figure. So, we don’t have enough information to understand where the cash went.

Resources consumed (i.e., accrual)

This, from the Statement of Profit or Loss and Other Comprehensive Income, is how the activities translated into expenses (with last year’s figures in the second column):

This is the only information about these items; for instance, we don’t know the breakup of the 35% of expenses labelled ‘Administration’. For instance, are all the employee benefits in this figure, or are some in one or more of the other expenses?

We are not told the destination of the money sent overseas (or locally). And there is nothing in the Financial Report 2020 on how The Alliance ensures that (a) the money reaches the overseas organisation (or the Australian ministries), and (b) is used for the purposes given.

Impact^[13]

Nothing systematic found.

Charity response

The Alliance invites neither feedback nor complaints.

Members of Missions Interlink, of which The Alliance is one, have to accept a set of standards. The introduction to these includes this statement:

We sent a draft of this review to The Alliance on 15 October 2021. They…did not respond.

1. See here for the previous review. ↑
2. https://missionsinterlink.org.au/about/ ↑
3. ↑
4. https://missionsinterlink.org.au/membership/mi-members-and-associates: ↑
5. A section in the article, Donating and Volunteering:
   • Focus on the nature of the charity’s work, its beneficiaries and the impact the charity is having in the community.
   • Is it clear what the charity is trying to achieve and how its activities work towards its objectives?
   • Would you like to spend your money, or time if volunteering, to support these objectives?
   • Is the charity being transparent about its activities?

   ↑

6. Associations Incorporation Act 1991: ↑ ↑
7. No doubt each Alliance church contributes to The Alliance, and therefore all those who give to Alliance churches are also potentially interested in the answer to this question. ↑
8. The constitution of the College at the time of its previous charity registration provides that ‘The National Board of The Christian and Missionary Alliance shall appoint a standing committee (referred to as the Governing Committee for The Alliance College of Australia), in accordance with the Rules of Association, which shall have the responsibility of promoting, administering and controlling the program of the College.’ [paragraph 3]. ↑
9. The constitution of the Development Fund [ACNC Register] provides that ‘The Development Fund shall only admit a person who is a member of the Church [The Alliance] and who the Church Executive has nominated in writing to the Board [paragraph 2.3]. ↑
10. The constitution of the Property Trust [ACNC Register] provides that ‘The Governing Body [CMAA board] shall be entitled to appoint persons to be members of the Trust and shall also be entitled subject to Article 8 hereof to remove them from such membership [paragraph 7]. ↑
11. The auditor, Bhaumik Bumia, a partner in the firm Hardwickes, once again agreed with their choice. This is what his professional body, Chartered Accountants Australia & New Zealand, has to say about the choice between the two types of reports [Enhancing Not-for-Profit Annual and Financial Reporting, March 2013, accessed from their website March 2020]:: ↑
12. The committee members are accountable to the members. The number of members is not disclosed. ↑
13. The ACNC has previously – the Fact Sheet is no longer on the site – explained impact this way: “Every charity has a mission that is associated with producing a public benefit. As this mission is pursued, the changes produced in individuals and their communities can be referred to as the charity’s ‘impact.’ If you are donating to a charity, you may wish to make sure that your donation is creating the greatest impact possible.’ There is no reason why this wouldn’t still be their view. ↑