Archived: The Church Missionary Society – South Australia Inc: charity review

This is a charity review of The Church Missionary Society – South Australia Inc (CMSSA), an organisation that seeks donations online, and is a member of Missions Interlink. (Including the answers to the questions that the Australian charity regulator, the ACNC, suggests that you ask.)

For last year’s review, see here.

Are they responsive to feedback?

• CMSSA do not seek feedback generally, but they do provide a way to complain or give feedback about privacy.
• CMSSA only invites complaints about its ‘safe ministry and professional standards’.
• Accountability is not mentioned on the website.
• I sent them a draft of this review. Just like the previous two years, they…did not respond.

Is CMSSA registered?

• As a charity, yes.
• Even though the short name for CMSSA in its constitution is ‘the branch’ – because it is a branch member of Church Missionary Society – Australia Limited (CMS-A) – the constitution also says that it is autonomous.
  • CMS-A is a ‘ministry organisation’ of the Anglican Church.
• CMSSA is a South Australian incorporated association (A1032).
• It trades under two other names, CMS SANT and CMS SA/NT. Neither these nor any other name is registered. It should therefore be using its full name in public (including ‘Inc/Incorporated’ on the end) at all times
  • Not as it does on Facebook, or on its webpages.
• CMSSA operates, per the ACNC Register, in South Australia and the Northern Territory.
  • If still doesn’t have the registration required to do business out of South Australia (an ARBN).
  • It says, in the AIS 2017, that it intends to fundraise, and it has an online invitation to give. However, it is not registered to fundraise in South Australia (there is no licensing regime in the Northern Territory), nor anywhere else^[1]. Is it because it thinks that it is exempt?

What do they do?

• The information under ‘What we do’ is not about CMSSA specifically, but about CMS generally (represented by CMS-A)
• There is one sentence in the AIS 2017 that is about CMSSA rather than CMS-Australia:
  • CMS SANT raises financial and prayer support for this work and encourages churches and individuals in SA & NT to grow in their understanding of and involvement with cross-cultural mission.
  • But this is not particular to 2017. For that see the Annual Report (on the Register).
• The Annual Report [page 4] says that CMSSA has 19 adult missionaries in ‘over 10 countries’. The Register says zero countries.

Does CMSSA share the Gospel^[2]

Via one or two of their missionaries, yes.

What impact are they having?

• No information found.

What do they spend outside the costs directly incurred in delivering the above impact, that is, on administration?

• If the unexplained ‘CMS-A Quota’, an amount that matches ‘Grants and donations made for use outside Australia’ in the AIS 2017, is defined as the money that goes to achieve the impact, then 33% is administration (down from 39% last year).
  • We don’t know how much administration is in the ‘CMS-A Quota’ figure though.

Do they pay their board members?

• The constitution does not prohibit this.
• There is no line item in the FY2017 Income Expenditure (sic) Statement and FY2018 Budget suggesting that directors are paid.

Can you get a tax deduction?

• Not for a donation to CMSSA.
  • Nevertheless, the giving page that they use, the one belonging to CMS-Australia, does offer tax-deductible giving.

Is their online giving secure?

• Security is still not mentioned.

Where were your (net) donations sent?

• The amount for the line item ‘CMS-A Quota’ in the FY2017 Income Expenditure (sic) Statement and FY2018 Budget is the same as ‘Grants and donations made for use outside Australia’. ‘CMS-A’ is most likely CMS – Australia. Beyond that we don’t know the destination of the money.

Is their reporting up-to-date?

• Yes (six months after their year-end, a month earlier than last year).
  • But if you are considering a large donation, I would ask for more up-to-date financial information – the accounts are for a year end that is now over 11 months ago.

Does their reporting comply with the regulator’s requirements?

• AIS 2017: Like last year, no.
  • Most of the figures in the Income Statement don’t match those in Financial Report.
  • The description of ‘activities’ is largely about another charity (albeit an associated one).
  • No outcomes are given.
  • Is ‘No’ the right answer to ‘Financial report submitted to a state/territory regulator?’
  • Two of the four questions in ‘Reporting to state or territory regulators’ are unanswered.
• Financial Report 2017: Like last year, no.
  • For 2017, the ACNC accepts the financial report CMSSA submitted to the state regulator as meeting its requirements.
  • The state regulator’s requirements are that ‘the accounts present fairly the results of the operations of the association for the financial year and the state of affairs of the association at the end of the financial year’ [section 35(2), Associations Incorporation Act 1985].
  • The committee of CMSSA have declared that the accounts meet this requirement. This is why they don’t:
    • By including monies collected for another charity, revenue is overstated by 40%.
    • Two of the four financial statements normally included are missing.
    • There are no Notes to the accounts.
    • One six-line ‘Concise Asset Statement’ is included in lieu of the required statement of financial position.
    • The FY2017 Income Expenditure (sic) Statement and FY2018 Budget does not comply with the Accounting Standards’ requirements for an income statement.
    • The auditor did not, as he says he did, follow the Australian Auditing Standards.
    • The directors don’t say, but the AIS 2017 and the auditor report that the financial statements are special purpose rather than the general purpose financial statements. For an organisation operating in 10 overseas countries, soliciting money online, and having 58 staff, this is not plausible.
    • Its relationship with CMS-Australia – the organization that collects its online donations and receives its money for missionaries – is not explained.
    • The relationship between the missionaries that it has sent overseas, employees, and CMS-Australia, is not disclosed.

What financial situation was shown by that Report?

• With the accounts departing so far from what is required, I say ‘No comment’.

What did the auditor say about the last financial statements?

• The auditor, Jeffrey T Byerley, CPA, issued a ‘clean’ opinion. This is a travesty when compared to the standards he should be following. See the section ‘Financial Report 2017’, above, for why.
  • Jeffrey is only qualified to do this audit because of the ACNC’s transitional provisions for reporting by incorporated associations:  the South Australian regulator doesn’t require the audit of CMSSA to be performed by a registered company auditor.

If a charity, is their information on the ACNC Register complete/correct?

• Almost – ‘Operates in (Countries)’ is blank.

What choices do you have in how your donation is used?

• Having been redirected from the CMSSA page to the ‘Give to CMS’ page, that is, to CMS – Australia’s giving page, your choices are:
  • ‘General Missionary Support’
  • ‘General Tax Deductible (sic) Gift’
  • ‘A particular worker’ (with a dropdown listing all the workers)

Who are the people controlling the organisation?

• Not shown on the webpages, but the ACNC Register (under ‘Responsible Persons’) says it is these people:
  • Benjamin Harrington
  • Philippa Harris
  • Robert Haynes
  • Andrew Jackson
  • Christopher Jolliffe
  • Barry Lock
  • Naomi Noakes
  • Tamra Purton
• The Board is responsible to the membership. The number of members is not disclosed.

To whom are CMSSA accountable?

• As a charity, to the ACNC.
• And to the South Australian regulator of incorporated associations.
• Although not mentioned on their webpages, they are accountable as a Member of Missions Interlink.
  • For one opinion on the strength of this accountability, see the section Activities in this review.

1. With no registration in Tasmania being assumed because the search facility was not available. ↑
2. “Good living and social concern are important [to the cause of evangelism], but they are not uniquely Christian graces…I’ve met a lot of fine Hindus, Muslims and atheists. Just living the life is not going to bring someone to Christ. There is much more to it than that. We must help people, certainly, but we must also share with them why we are motivated to do so. We must stand against injustice, poverty and need, but we must at the same time point to the One who brings justice and who can meet the deepest need. Until they know our reasons, how can they come to know our Lord?” [Dan Armstrong, the Fifth Gospel: The Gospel According to You, Anzea Books, pp. 13-14. ↑