Tag: GFAECFAletter

Gospel for Asia and Compliance with ECFA’s Standards: The 2015 Letter, Part 6

After about a month break, I am resuming this series.

In CEO and founder K.P. Yohannan’s recent “exclusive personal response” to the fraud lawsuit settlement involving Gospel for Asia, Yohannan traces GFA’s problems to a 2015 “confidential letter from a financial standards association we were part of, and of which we were a charter member.” That letter was from the Evangelical Council for Financial Accountability and outlined 17 potential violations of ECFA financial standards. In October 2015, ECFA evicted GFA from membership. To help donors understand the nature of the concerns ECFA had about GFA, I am posting the concerns one at a time with commentary. You can read all of the posts by clicking this link.

Read the entire ECFA letter on GFA’s compliance issues here.

From that letter, here is the sixth compliance issue:

6. GFA solicits funds for narrower purposes than the eventual expenditure of the funds.

During ECFA’s review on August 12, GFA staff provided a document to demonstrate the flow of funds from GFA to field partners. ECFA learned that donor-restricted donations are appropriately tracked by particular revenue classifications. However, we also discovered, and it was confirmed by GFA staff, that the disbursement of the gifts are tracked in much broader categories. For example, donations were received and tracked for 38 different specific items including kerosene lanterns, bio sand filters, chickens, manual sewing machines, blankets, bicycle rickshaws, and others, but related expenses were only tracked as “community development.” In other words, donations were raised for 38 specific items, with the donations pooled for expenditure purposes instead of expending them specifically for the purposes raised.

ECFA did not find any evidence that donors to the 38 different giving categories had awareness that their gifts were grouped and used in a broader category than the specific categories in which the gifts were raised. ECFA’s staff raised concerns regarding GFA’s compliance with ECFA Standard 4, 7.1, and 7.2 in raising funds for a particular purpose but then failing to document the actual use of those funds by the particular donor-restricted purpose.

Subsequent to this conversation, on August 16, GFA staff indicated that GFA field partners will begin tracking expenditures by specific item accounts to provide adequate transparency as to the use of designated funds.

Our review of the board minutes did not indicate the GFA board had approved, or even been notified, that gifts solicited for very specific purposes were not being expended with the same specificity as the gifts were raised.

GFA led donors to believe their funds had been spent for specific items but there was no way to know if such intent had been followed since there was no documentation of that use. This policy had not been approved by the board. However, after this the board would have been alerted via the letter.

Francis Chan was on the GFA board by this time and had reassured people that he had sent in personal auditors to make sure funds were being spent as intended. Here is a May 15, 2015 email from his organization Crazy Love to me:

He has even gone to the lengths of sending two different auditors/accountants to research their financial practices. Both have come back with glowing reports.

His auditors/accountants missed a whole bunch of violations of ECFA standards. Chan continues to use this story. However, we know that GFA was kicked out of ECFA in October for numerous violations. GFA promised that they would reapply for ECFA membership which they have not done. GFA has not released audited financial statements. They have not disclosed to donors that their charity registration in India has been revoked.

Next: GFA’s financial statements do not appropriately report transactions with foreign partners.

Gospel for Asia and Compliance with ECFA’s Standards: The 2015 Letter, Part 5

In CEO and founder K.P. Yohannan’s recent “exclusive personal response” to the fraud lawsuit settlement involving Gospel for Asia, Yohannan traces GFA’s problems to a “confidential letter from a financial standards association we were part of, and of which we were a charter member.” That letter was from the Evangelical Council for Financial Accountability and outlined 17 potential violations of ECFA financial standards. In October 2015, ECFA evicted GFA from membership. To help donors understand the nature of the concerns ECFA had about GFA, I am posting one of the concerns each day. You can read all of the posts by clicking this link.

Read the entire ECFA letter on GFA’s compliance issues here.

From that letter, here is the fifth compliance issue:

5. Lack of discretion and control over funds granted to foreign entities. During our review on June 3, ECFA staff raised questions regarding GFA’s oversight and control of funds sent to foreign field partners. GFA’s staff indicated that the foreign field partners are completely independent organizations and therefore GFA did not exercise any direct control over field partners. GFA staff also indicated that they did not have a foreign grant process in place to oversee the use of funds.

Given legal requirements on tax-exempt entities to have appropriate discretion and control over the use of funds sent to foreign entities, ECFA staff indicated that GFA’s lack of a grant process appears to violate ECFA Standard 4’s requirement to follow applicable laws.

Subsequent to these conversations, on August 21, GFA staff indicated a new foreign grant process was developed with the assistance of its new audit firm and will be in effect as of September 1, 2015.

Our review of the board minutes did not indicate the GFA board had approved, or even been notified, of GFA’s minimal oversight of funds provided to field partners.

For reasons I cannot explain, GFA has publicly claimed no control over what happens with donations in Asia. K.P. Yohannon has repeatedly claimed that he is not on any boards in Asia. As recently as last month, he told Francis Chan, he has no more control over Believers’ Church than the other Bishops.

This claim was thrown into doubt during the fraud lawsuit due to discovery of an email from Chief Operating Officer David Carroll to K.P. Yohannan. In it, Carroll said to Yohannan:

We can say all we want that we don’t have anything to do with the Believers Church or the field and that you are only the spiritual head of the church and that finances are handled by others but you, but as a practical matter, that will not hold up.

The Believers’ Church constitution makes it clear that Yohannan is the final and supreme authority in temporal and spiritual matters. Perhaps GFA didn’t want to own up to the level of control Yohannan possesses.

In any case, the claim that Believers Church and GFA-India (now known as Ayana Charitable Trust) had no input from Yohannan seems implausible. At this time, both charities in India are barred from accepting foreign funds since their registration as charities was revoked in 2017.  GFA-USA is sending funds to NGOs which act as shell organizations for the purpose of funneling money to Believers’ Church.

Donors should know that funds given to GFA don’t go directly to GFA in India.  Some funds go to other nations in Asia but most goes to entities in India that have no operational presence in the country. They exist to receive funds and give them to Believers’ Church or some other BC controlled entity. I have asked various authorities if this is allowed but have not received an answer as yet.

Next post: 6. GFA solicits funds for narrower purposes than the eventual expenditure of the funds.

 

Gospel for Asia and Compliance with ECFA’s Standards: The 2015 Letter, Part 4

In CEO and founder K.P. Yohannan’s recent “exclusive personal response” to the fraud lawsuit settlement involving Gospel for Asia, Yohannan traces GFA’s problems to a “confidential letter from a financial standards association we were part of, and of which we were a charter member.” That letter was from the Evangelical Council for Financial Accountability and outlined 17 potential violations of ECFA financial standards. In October 2015, ECFA evicted GFA from membership. To help donors understand the nature of the concerns ECFA had about GFA, I am posting one of the concerns each day. You can read all of the posts by clicking this link.

Read the entire ECFA letter on GFA’s compliance issues here.

From that letter, here is the fourth compliance issue:

4. The level of urgency communicated in GFA donor appeals contrasted with reserves held by foreign field partners and delays in sending funds to the field. In light of the significant cash balances held by field partners and the delay in sending funds to the field, ECFA staff raised concerns about the appropriateness of communicating urgency in many donor appeals. This includes appeals indicating “When we share with you about the urgency to reach the untold, lost millions—and the opportunities to win them to Jesus—it is not done to produce feelings of guilt or manipulate.” One appeal we reviewed indicated “One blanket, like the one Hetaksh received, will literally make the difference between life and death for them and especially for their small children and elderly relatives.”

The delay between when a donor gives a gift and when the funds are actually made available for designated purposes on the field is inconsistent with the level of urgency in many appeals and the timeliness of using donor-restricted funds as required by ECFA Standards 7.1 and 7.2. On August 12, GFA staff indicated that despite the delay in making foreign contributions available to carry out programmatic work, at least some designated funds were disbursed on a timely basis through the use of field-generated income.

Our review of the board minutes did not indicate the GFA board had approved, or even been notified, of GFA’s practice of soliciting funds based on urgency with a corresponding delay in disbursing funds to the field.

GFA Recycles Urgency

Even after being called out for this in 2015, GFA used this same urgent appeal in 2017. In a 2017 Patheos article, an anonymous GFA staff person recycled this appeal as follows:

To Hetaksh’s surprise, God answered his prayer for financial breakthrough in a very practical way—and just before winter started, too: He and his family received a thick, warm blanket!

This blanket came as a gift through Pastor Mrithun’s church during a blanket distribution to the poor—a distribution sponsored by our dear Gospel for Asia friends around the world. The blanket was big enough to keep the whole family warm at night, night after night, throughout the entire cold season.

This visible sign of God’s love and care greatly encouraged Hetaksh. No doubt the Lord will continue to care for this precious family and make them a powerful witness to others.

Urged to Give

Every winter, our partners in Asia feel the urgency of those around them, and we do, too. They pray for means and opportunity to distribute thousands of blankets and articles of winter clothing among those who lack adequate shelter and clothing to survive the freezing cold temperatures. They know that one blanket, like the one Hetaksh received, can make the difference between life and death for a family, especially for small children and the elderly.

It’s crazy to realize what a blanket can do. They are so small, but they work. For those who don’t have extra blankets for every family member, like we may, one blanket can mean a whole lot.

This recycled story (who knows if it is true) of Hetaksh  is presented as if it is current and represents an urgent need. In fact, GFA has had millions sitting in accounts and could have provided thousands of blankets. Instead, some of that money eventually went to other projects and some went to complete the Wills Point headquarters.

It is hard to believe that GFA was called out for this very appeal in 2015 and then reused it in 2017. So few people know about the ECFA report that apparently the GFA marketers believe it won’t matter.

Gospel for Asia and Compliance with the Evangelical Council for Financial Accountability’s Standards: The 2015 Letter, Part 3

In CEO and founder K.P. Yohannan’s recent “exclusive personal response” to the fraud lawsuit settlement involving Gospel for Asia, Yohannan traces GFA’s problems to a “confidential letter from a financial standards association we were part of, and of which we were a charter member.” That letter was from the Evangelical Council for Financial Accountability and outlined 17 potential violations of ECFA financial standards. In October 2015, ECFA evicted GFA from membership. To help donors understand the nature of the concerns ECFA had about GFA, I am posting one of the concerns each day. You can read all of the posts by clicking this link.

Read the entire ECFA letter on GFA’s violations here.

From that letter, here is the third compliance issue:

3. Delay in sending funds to the field. It was not until the meeting on August 12 that we learned that $47,898,342, or approximately 82%, of gifts received by GFA in 2014 designated for India were not sent to the field until the last two days of the calendar year.

To be clear, nearly $50 million of gifts were raised from January to December, with only modest amounts sent to the field until the end of the year. ECFA staff expressed concern over failing to send gifts to the field on a timely basis, raising compliance issues under ECFA Standards 4, 7.1, and 7.2, particularly given the urgent nature of many GFA gift solicitations. Subsequent to this discovery, GFA staff indicated that field partners requested the delay of sending the funds to the field due to challenges in transmitting funds into India. ECFA could not confirm if the delay in transferring the funds was justified.

Based on ECFA’s review of GFA’s internal financial statements as of June 30, 2015, GFA had a cash balance of $28,338,841 in funds designated for foreign field partners, or more than the total of all funds received for the field in the first half of 2015. In other words, the practice of sending funds to the field on a significantly delayed basis was not only followed for 2014 but also during the first half of 2015.

GFA staff informed ECFA on August 12 that part of the cash balances held by GFA on June 30 were transferred to field partners during the month of July. On August 21, GFA staff indicated there is now a plan to send funds to field partners on the 15th of each month.

When ECFA staff asked if the board was apprised of the delays in transferring funds to the field, GFA staff indicated the board was informed of this fact because the board received periodic financial statements. However, the internal financial statements erroneously reflected field funds as a liability and as an expense immediately upon receiving the funds. Thus, it would have been very difficult for the board to learn of the delays in sending funds to the field because the interim financial statements indicated the funds had been sent to the field when they had not. Therefore, ECFA found no indication that the board had approved, or even been clearly informed of the questionable practice of delaying sending funds to the field.

One of the reasons former GFA board member Gayle Erwin resigned related to his realization that he was being kept in the dark about how funds were spent. In this case, funds were being held from the field. Even though GFA representatives urgently solicited donations, the funds were not sent until near the end of the year.

There was no problem in submitting funds to India. However, the field partner Believers Church (K.P. Yohannan is the head of that church as well as CEO of GFA) may not have liked the scrutiny of the Indian government. Spacing out donations might have been part of their plan to manage foreign contributions. However, it is still unclear to me why GFA held back so much money.

In any case, GFA raised millions and held it for several years all the while begging for funds. The next post will deal with that problem directly.

Next post: 4. The level of urgency communicated in GFA donor appeals contrasted with reserves held by foreign field partners and delays in sending funds to the field.

Gospel for Asia and Compliance with the Evangelical Council for Financial Accountability’s Standards: The 2015 Letter, Part 2

In CEO and founder K.P. Yohannan’s recent “exclusive personal response” to the fraud lawsuit settlement involving Gospel for Asia, Yohannan traces GFA’s problems to a “confidential letter from a financial standards association we were part of, and of which we were a charter member.” That letter was from the Evangelical Council for Financial Accountability and outlined 17 potential violations of ECFA financial standards. In October 2015, ECFA evicted GFA from membership. To help donors understand the nature of the concerns ECFA had about GFA, I am posting one of the concerns each day. You can read all of the posts by clicking this link.

Read the entire ECFA letter on GFA’s violations here.

From that letter, here is the second compliance issue:

2. Excessive cash balances held in partner field accounts. Allegations were made that GFA had upwards of $150 million in partner field accounts, far more than necessary to provide appropriate operating reserves. During our visit on June 3, ECFA was informed that GFA field partner cash reserves were approximately $7 million. After ECFA requested detailed documentation of cash balances held by foreign field offices, on June 29, we discovered that GFA’s field partners had $259,437,098 on hand at March 31, 2014 and approximately $186 million in June 2015.

ECFA staff questioned the appropriateness of the high levels of cash being held in partner field accounts. We were told that GFA partners felt it was important to maintain the high balances in case the Indian government decided to block funds being transferred into the country.

The source of the balances was primarily from donor-restricted gifts to GFA, often raised in response to gift solicitations that communicated urgent field needs (see #4 below). ECFA staff expressed concern that the high reserves may not comply with ECFA Standards 4 and 7.1. Subsequent to our conversation on this matter on July 27, GFA provided ECFA with a plan to reduce partner field account reserves to $72 Million, and then amended the plan on August 27 to reduce reserves down to $11 Million. Again, GFA staff disclaimed that GFA exercises any control over field partners (see #10 below).

In our meeting on July 1, ECFA staff asked you what the GFA board would think if they knew of the high balances in partner field accounts. You indicated that neither the board nor you were aware of the magnitude of the balances. You responded, “They would be as surprised as I am.” Subsequently, the GFA board was notified, during their July 13 board meeting, of the balances held by field partners.

In the Spring of 2014, GFA had a quarter of a billion dollars in accounts from donors. At the same time, GFA representatives, including K.P. Yohannan, begged donors for money, the organization was sitting on incredible wealth. In May 2015, I publicly asked why GFA was sitting on $158-million.  At that time, GFA leaders told the staff that only $7-million was available. As noted in yesterday’s post, much of that money was sitting in accounts earning interest and not helping widows and orphans.

In 2017, the government of India did block GFA from receiving foreign funds. However, several NGOs in India are still getting money from GFA in the U.S. although it is not clear where that money is being used.

Note that this point has nothing to do with GFA’s accounting firm or practices.

Next: 3. Delay in sending funds to the field.