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.

Liberty University Protesters Want Investigation of Falwell

A student protest is planned this morning at Liberty University. Specifically, the students want an investigation of issues raised in the Politico article by Brandon Ambrosino about Jerry Falwell’s personal and business dealings.

Elizabeth, a LU student, is organizing the event which is slated for 11:45am.

The students have the following mission statement:

Our mission statement is to bring to light the truth of these allegations of various misconduct as brought forth by the Politico Magazine article. We are demanding and investigation both internal and external.

#StudentsForChange is the hashtag the group is using for news about the protest. There isn’t much now but there might be more during and after the event. Falwell has a compliant board but it remains to be seen what student unrest will do to his support.

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

In 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.” He said that the letter was put on social media to damage GFA. He added that a former staff member sent negative letters to donors.

Some of that is true and some is misleading. The letter Yohannan referred to came from the Evangelical Council for Financial Accountability and was given to me by Gayle Erwin, a former GFA board member who served on the board for 30 years. Erwin had resigned from GFA’s board because of multiple problems he saw at GFA. He wanted to correct GFA’s public statements and believed the donor public would only know the truth if they had information. Erwin’s motive was to inform donors and set the record straight. If informing donors damages GFA, then GFA should consider the implications of that.

Yohannan also said a former staff member sent negative letters. In fact, a group of former staff members approached GFA’s board many months in advance of any public revelations. Long before I published my first blog post about GFA, former staff members approached GFA’s board with 5 concerns which they hoped could be resolved without public disclosure. In this newest statement, Yohannan presented the situation with former staff as though he was surprised by it. He should not have been. The situation had been brewing for months before anything came to light. You can read the concerns and history of the situation at GFADiaspora.com.

K.P. Yohannan said that the allegations were false. However, the board member he assigned to look into the matter — Gayle Erwinfound evidence for all but one of the five concerns.  He later changed his view about the last concern and said he agreed with the former GFA staff on that point as well. Erwin also alleged in 2015 that Yohannan altered Erwin’s report to the GFA board to minimize the severity of Erwin’s findings. Those interested in comparing Yohannan’s statements now to former GFA board member Erwin’s documents and statements from 2015 can see them here. I also intend to post excerpts from Erwin’s report over the next several weeks.

For now, I want to respond to this part of Yohannan’s response:

Every year we evaluated our ministry and underwent an independent audit. In 2015, our governing board received a confidential letter from a financial standards association we were part of, and of which we were a charter member, pointing out that our accounting practices needed to better conform to the requirements set by that association. Despite the unique challenges our organization faces by supporting ministry in certain parts of the world, we immediately set out to comply with their request and hired a new auditing firm.

This paragraph appears to blame GFA’s former auditor Bland Garvey for the lack of adherence to ECFA’s financial standards. In fact, the ECFA didn’t specifically request that GFA change firms. The ECFA listed 17 items of concern; in two of them the ECFA listed problems with accounting practices. In one of them, GFA said they had already changed firms without a request from the ECFA. In fact, most of the matters related to financial practices within the control of GFA’s leadership.

To focus attention on matters of interest to the public which have been obscured by GFA’s response to the lawsuit, I am going to post segments of the ECFA compliance letter on the blog over the next month. Interested readers can read the entire letter by clicking this link. However, starting today, I will take each section in a post and highlight elements of what ECFA found. The reasons ECFA evicted charter member GFA weren’t limited to problems with the accounting firm. I will take them in order from the letter to K.P. Yohannan dated September 2, 2015:

The following is a summary of the most significant GFA compliance issues we reviewed:

1. Use of field-generated funds to satisfy designated foreign contributions. During our meeting on July 1, ECFA first learned that GFA and its field partners have engaged in a multi-year practice whereby field partners at least partially satisfied the designations on foreign contributions (primarily from U.S. donors, restricted for field use in India) by using locally generated field income (contributions from donors in India, profits from an India based rubber plantation, hospitals, etc.).

GFA staff indicated that the purpose of this practice was to retain foreign contributions in Indian Foreign Contribution (FC) accounts to earn a higher interest rate while expending locally generated funds that would not earn the higher interest rate. At this point, it is important to note that GFA disclaims that it exercises any control over field partners (see #10 below).

GFA staff also indicated that amounts in FC accounts would be used eventually for their original designation, as well, with the ultimate result that the purpose of the foreign contributions would be more than fulfilled.

To be clear, GFA solicited funds from donors, primarily gifts with donor restrictions, and transferred the funds to field partners in India, depositing them in FC accounts. While certain amounts were expended from the FC accounts in fulfillment of donor designations, significant amounts were retained in FC accounts over a period of years (see #2 below).

ECFA staff observed to GFA that it is not a normative practice to hold donor-restricted gifts and fulfill donor restrictions using other funds. Especially with respect to funds sent to international partners, it is extremely difficult for GFA to demonstrate that it has exercised appropriate control of the funds. Further, ECFA observed that this practice may not comply with ECFA Standard 7.2 because of the lack of clarity regarding the satisfaction of donor restrictions on gifts solicited by and given to GFA.

Our review of the board minutes did not indicate the GFA board had approved, or even been notified of, the practice of using field generated funds to satisfy restrictions on foreign contributions.

Subsequent to ECFA learning of this practice on July 1, GFA represented to ECFA that GFA’s field partners have ceased the practice of satisfying the designation on foreign contributions with field-generated funds.

GFA acknowledged using money from Indian for-profit ventures and Indian donors to fund activities which donors from the US thought they were funding. US funds were being placed in interest bearing accounts. One problem with this is that field partners might not use those foreign funds for the purposes designated. Some funds were held for many years while donors thought their donations had been spent to help evangelists or children. GFA couldn’t satisfy the ECFA that those funds had been used to satisfy donor intent. This was replicated in the fraud trial which led to the federal judge sanctioning GFA because they were unable to produce evidence about how the funds matched up with donor designations.

Next post: Excessive cash balances held in partner field accounts.

Is There a War on Psychotherapy?

Last week, this came across my path:

I assume Christopher Doyle refers to the effort around the country to prohibit sexual reorientation change efforts for minors. However, I write this post to address a couple of points.

When it comes to sexual orientation and psychotherapy, the reparative therapy narrative of defective parenting doesn’t hold water or match up with research or experience.  However, there are still therapists who believe that and try to impose it on their clients and their families. Much of my work has been to develop a therapy approach (sexual identity therapy) which requires therapists to present scientific research about sexual orientation to clients and allow clients to decide what to do about it.

On the other hand, the Family Research Council speaker Christopher Doyle worked and trained with Richard Cohen who has a different approach. Here is a snapshot of a couple of Richard Cohen’s techniques.

I will leave it to readers. Is this psychotherapy?

Doyle defended these and other outrageous techniques in this legal brief designed to be used in a New Jersey trial involving JONAH, a Jewish change therapy group. JONAH lost at trial.

You can see Doyle in action in this review of a documentary called Sunday Sessions in which Doyle provides sexual orientation change counseling to a young adult man. Note that Richard Cohen is involved in the group sessions at the beginning.

In the end, the young man feels somewhat better but credits the teachings of the Catholic church for his mood improvement. There is no indication that his sexual attractions changed.

Sexual Identity Therapy

I watched the documentary (I recommend it although there is no real conclusion to the story), and I need to make another thing clear. In the film (and on this page), Doyle calls his approach to therapy “Sexual Identity Affirming Therapy.” I want to say plainly that what he does is unrelated to “Sexual Identity Therapy” as developed by Mark Yarhouse and me.

In the documentary, Doyle did not provide a range of information about the development of male homosexuality but instead authoritatively expressed the reparative narrative of weak fathers and an unmasculine upbringing. The directive style demonstrated in the movie review above is not taken out of context. None of this is consistent with sexual identity therapy. People working within the principles of SIT do not attempt to change a client’s sexual orientation. SIT is antithetical to what Doyle demonstrates in the documentary and more broadly, to what Cohen does in his various public demonstrations.

The War is Over

In my opinion, within psychotherapy, the war is actually over and change therapy has lost. No training programs teach it. I know of no Christian training programs that teach it (although I would like to be corrected if I am wrong). It is misleading to pretend there is a wronged group of psychotherapists who want to practice it and can’t. The courts have not been inclined to defend it.

On the other hand, there has been a resurgence of interest in ex-gay type ministries. While I don’t yet see an accompanying revival of professional interest in change therapy, it is the nature of true believers to keep trying.