Indian Tax Court on Gospel for Asia and Believers' Church: "Substantial Income" Not Used for Intended Purposes

In 2014, an Indian tax court considered a claim against Gospel for Asia and Believers’ Church. According to a court filing dated December 12, 2014, Gospel for Asia and Believers Church spent more of their income than allowed on purposes not related to the reason they were formed. Doing so made that income taxable. Gospel for Asia and Believers’ Church together appealed the assessment of tax, saying that the use of the funds were given to related organizations which had charitable purposes. The court found that funds were still being used for unintended purposes and remanded the matter back to the tax assessor. I have been unable to find any documentation of how much GFA and BC had to pay or if the matter has been resolved.
You can read the whole thing at this Indian site where public records are archived. I have pulled out the relevant portions below:

Shri M Anil Kumar, the ld.DR submitted that both the assessees are registered as charitable trust u/s 12AA of the Act. During the year under consideration, the assessing officer found that both the assessees have given loan to other trusts from the unutilised portion of the income which exceeded more than 15%. Referring to section 13(1)(d)(i) of the Act, the ld.DR submitted that the assessee trust invested its funds in the form/mode otherwise than prescribed in section 11(5) of the Act. Therefore, according to the ld.DR, there was violation of section 11(2) r.w.s. 13(2)(d) of the Act. According to the ld.DR, the assessee is not entitled for any exemption.

Assessees refer to Believers’ Church and Gospel for Asia. Both are registered as charitable trusts. Both groups had income during the 2010-2011 tax year and loaned more than the allowed 15% to other charitable trusts related to GFA and BC. Originally, the tax assessor considered those loans improper investments which meant that the income invested was not exempted from tax. The original complaint of the tax assessor was eventually set aside in favor of another interpretation by the tax court and remanded back to the tax assessor for reassessment of tax.
GFA and BC had the following interpretation of tax law. The “ld.representative for the assessee” refers to GFA’s and BC’s representative.

On the contrary, Shri Venkitachalam, the ld.representative for the assessee submitted that both the assessees advanced funds to other registered trusts which have similar objects. According to the ld.representative, the assessee advanced funds to BCMET for construction of hospital building. BCMET is also a registered trust u/s 12AA of the Act. The ld.representative further submitted that Carmel Education Trust also a registered charitable trust u/s 12A of the Act was given funds by the assessee to carry out their charitable activities. According to the ld.representative, when the funds were advanced to other similarly placed charitable trusts, amounts to application of income; therefore, the provisions of section 11(2) are not applicable. The ld.representative further submitted that advancing money to similarly placed charitable trusts does not amount to investment or deposit. Therefore, there is no violation of section 11(5) of the Act also.

GFA and BC “advanced funds” to related trusts, one involved in building Believers Church Medical College Hospital and the other an educational trust which operates various schools. I don’t know for certain, but it sounds like the educational trust was given funds to help fund operating expenses. The BC’s hospital was given money for construction of the state of the art facility. Thus, BC and GFA took income on donor money and used it to fund the hospital and engineering school.
The court considered both sides and concluded that “substantial income” of GFA and BC was not used for “the purposes for which they were formed.”

We have considered the rival submissions on either side and also perused the material available on record. It is not in dispute that substantial income of the assessee trust was not used by both the assessees for the purposes for which they were formed. (emphasis added)

The court said there is no question that GFA and BC misused the funds. The main question was about how to treat those funds for tax purposes. After going through an evaluation of Indian law relating to the facts of the case, the court ruled as follows:

Therefore, in view of the latest development of law with effect from 01-04-2003 if the income is paid or credited to another trust or institution even though they are registered u/s 12AA or approved u/s 10(23C) of the Act, the same has to be treated as income of the assessee.

Believers’ Church Hospital and Medical College

Since GFA and BC loaned/advanced more than allowed by law, that income has to be treated as income of the two organizations. The court then sent the matter back to the tax assessor to figure out what GFA and BC owed.
I can’t find any additional cases or appeals so the matter might still be active. I asked GFA what happened in the case but, as usual, received no answers.
Donors have questions but all they are getting are assurances that their donations are going for the purposes intended. This case provides one more basis to question that claim.
This case adds one more item to the growing list of concerns about GFA’s financial affairs.

Indian Newspaper: Gospel for Asia and Believers' Church Threaten Newspaper, Claim Defamation of the Metropolitan

This seems like an odd way to evangelize.
I can’t read the Malayalam but the English indicates that GFA-India and Believers’ Church are threatening (or have filed, I can’t tell for sure) a defamation suit against a paper in Kerala India (“Breaking News Weekly”). If this is accurate, GFA-India and Believers’ Church are demanding $15.7 million for defamation which includes calling K.P. Yohannan by his name instead of referring to him as Metropolitan Bishop.
I am seeking a translation but for now here is the “legal notice” according to the paper.
Defamation suit1
Defamation suit2
Note that the letter says calling K.P. Yohannan by his name is defamation. He apparently is to be addressed as Metropolitan Bishop. The next two pages pull out Malayalam passages from the paper which GFA/Believers’ Church believe to be defamation. Here is page three and four. Page five is below.
Defamation suit3 Defamation suit4 Defamation suit5
This is all that was provided by the Indian newspaper. The amount demanded in U.S. dollars is $15.7 million (100 Crores). The lawyer wants that sum in 7 days.
If this is true, it won’t be the first time GFA/Believers Church have sued in India. You can use this website to read cases where GFA has been sued and has sued various parties in India.

Francis Chan Joins Gospel for Asia Board Meeting Today; Is He Still Skeptical?

Last week, I publicly asked pastor Francis Chan for some answers regarding Gospel for Asia, a ministry he has endorsed. Today, I learned from a source at GFA that GFA’s board is meeting in Wills Point today with Francis Chan in attendance. It is not clear if Chan is there as a new board member, as has been rumored, or if he is there to be skeptical and ask questions. In any case, this heightens expectations that perhaps GFA leaders might break their silence. 

If Chan does join the board, that might help to address concerns but not just by joining. The expectation is that he would use his position on the board to create a culture of transparency. If he doesn’t do that, the impatience of donors and the public will grow.

As a summary, here are some concerns for GFA.

While these are not the only problems, getting some information about them would be a good start.

Francis Chan: Can You Get Some Answers From Gospel for Asia?

Some time ago I emailed Francis Chan ab0ut his endorsement of Gospel for Asia. Chan says on the video below that he is skeptical and because of that he sent people to check GFA out. I was told by his assistant Chaz that he was getting my emails, but it was unlikely that I would get a personal response from Chan. And as Chaz predicted, I have not heard from Chan in response to concerns I raised in the emails and blog posts.

Watch Chan’s endorsement of GFA.

Rev. Chan, like you, I am skeptical, but unlike you, I don’t have a budget that allows me to send people to check GFA out. However, I have asked GFA multiple times for help understanding why their 2013 audited statement says they sent $58.5 million to GFA-India in 2013 but only $6.5 million shows up in GFA-India’s reports to the Indian government. I can account for another $22 million that GFA in the U.S. sent to Believers’ Church and two other NGOs controlled by K.P. Yohannan but that leaves about $30 million unaccounted for. It seems like a discrepancy like that would make a skeptical person wonder what happened to the $30 million.

If you or your auditors know anything about the unaccounted for $30 million, could you let me know? If there is a reasonable explanation for this, then it seems odd that GFA has allowed the situation to go on without public disclosure. The ECFA is no help either. All the silence makes a skeptical guy like me wonder what is happening. However, it seems like you might know something and perhaps could reassure donors and the public.

Also, there are some other matters which you could really help with:

Rev. Chan, many people trust you, and like you, I am skeptical and don’t believe it is wrong to ask questions. Perhaps, you know something about these matters and could persuade GFA to simply offer additional information and explanation. Or perhaps you, as an endorser, could write and clear things up. We aren’t the only ones who are skeptical, others too want to know what is happening at GFA.

I hope to hear from you.

Will the Evangelical Council for Financial Accountability Hold Gospel for Asia Accountable?

I am not betting on it.
CashThe Calvary Chapel Senior Pastors Conference ended yesterday with no public statements from anyone within the Calvary Chapel movement about Gospel for Asia. GFA exhibited at the conference but left their table unmanned much of the time according to sources there. Several pastors, speaking on condition of anonymity, told me that their church would soon drop support for GFA due to GFA’s public silence about various financial, personnel and leadership concerns.
Several sources have told me that GFA is holding up their membership in the Evangelical Council for Financial Accountability as proof that no real problems exist. Furthermore, GFA insiders have told me that ECFA executives have reviewed GFA’s finances and is privately expressing confidence in GFA. ECFA leaders have ignored my requests for clarification or explanation about the missing money, money carrying to India, etc.
Mars Hill Church similarly pointed to ECFA membership as an indication that funds were being used properly. Even as the church did that, Mars Hill made changes to their procedures to come more into compliance with ECFA guidelines. What I learned about ECFA via the Mars Hill experience and then later through ECFA’s handling of Faith Christian Church is that donors cannot count on ECFA to disclose problems with members.
Now ECFA membership is being used by GFA to avoid explanations of multiple concerns raised by around 100 former employees, former donors, and bloggers. In my opinion, ECFA is now responsible for whatever problems GFA manifests. Here again is a summary of issues that GFA and ECFA have ignored.

Millions of dollars are unaccounted for and GFA has not given any reasons or explanations. Now GFA is claiming that ECFA has seen the books and has given the all-clear.
Since GFA won’t be accountable, I publicly call on ECFA to provide information relevant to list of concerns listed above.

Gospel for Asia Exhibiting at Calvary Chapel Pastors Conference; Any Answers There?

Earlier today, Danny Yohannan (K.P. Yohannan’s son and in leadership at Gospel for Asia) tweeted the following:

GFA is exhibiting at the Calvary Chapel Senior Pastors Conference (watch live here). I wonder if GFA will address any of the CC pastors’ questions.
Tomorrow will be two months since GFA told me they would answer no more questions. GFA reps have time to exhibit at this conference but they can’t be bothered to address other matters such as:

In addition to the “awesome free materials” perhaps Mr. Yohannan could give some free answers to these questions. If anyone attending the Calvary conference gets any responses, please add that information in the comments or send me an email.

Former Gospel for Asia Staff Respond to K.P. Yohannan's Donor Letter: GFA Leaders Never Followed Through

Yesterday, I posted an email that Gospel for Asia donor services is sending to donors about the recent controversies, many of them disclosed on this blog. Today, the former staff have posted a response to the question: Is Diaspora willing to meet with GFA?
The letter from GFA CEO K.P. Yohannan did not address the questions about GFA’s financial dealings but did indicate that the former staff (now around 100) were to blame for lack of face-to-face meetings. This reply provides the other side of the matter.
To the question, is the Diaspora willing to meet? They say:

The short answer is: Yes.
However, we doubt there continues to be a reason to meet.

Diaspora had hoped from the beginning to meet with GFA leadership to address the concerns voiced in our first letter. As we moved forward through this process, we even chose a date with KP for such a meeting (October 2, 2014 and then October 13, 2014), but GFA’s leadership never followed through in actually sitting down to meet. Instead, we were told that Gayle Erwin was heading an investigation into our concerns and, as such, it was now out of KP’s hands and up to the board as to what to do next.

A part of the results of the investigation, according to the Diaspora, was a statement that GFA saw no reason to meet.

Several months passed until Gayle Erwin sent his final report in March stating that our claims were dismissed and that they would no longer be communicating with us. We took that to mean an end of any opportunity for a meeting to take place.

The Diaspora explain their reasoning for commenting publicly and deny that a demand for videotaping was the deal breaker:

We have been told that GFA is telling supporters that the only reason the meeting has not happened is because “Diaspora would not meet without it being videotaped” and GFA has been counseled against doing so by the ECFA. Therefore, they have accused us of not being willing to meet.
We think this is disingenuous, as it gives the impression that GFA did all they could to arrange a meeting and the only thing that led to failed negotiations was our demand that it be videotaped (see Aug 22, 2014). This is simply false. Again, see our Communications History for the whole truth.
The only meeting negotiations between GFA and ourselves were the emails and calls between JD and KP. If one reads, s/he will find that JD asked one time about it being videotaped and KP never even responded to that. Then KP announced the investigation. After that, the negotiations about meeting times simply stopped and KP never spoke directly to JD after that. We would not call that a failure on our part.

I encourage interested readers to examine the communications history and responses to other questions from the former staff group.
The GFA response so far appears to be to claim they want to be transparent but actually not be transparent. They have ignored calls to provide information which would address the many issues which have been raised.  I hope that will change. The silence from GFA is very loud.

Gospel for Asia Avoids Tough Questions, Continues the Spin

Beginning in mid-June, some donors and former donors to Gospel for Asia began receiving a letter from GFA CEO K.P. Yohannan. That letter is below. Yohannan doesn’t actually address any of the matters of smurfing money to India, surpluses in India, funds unaccounted for and the role of Yohannan in the Believers’ Church.
I am going to provide the letter along with my comments.

Subject: Gospel for Asia
Dear Friend in Christ,
Greetings in the name of the Lord and Savior Jesus Christ! Thank you for your commitment to the Great Commission and to Gospel for Asia’s role in seeking its fulfillment. While there is much to share with you about how God is working through Gospel for Asia and how we are seeking to reach the millions of souls still waiting to hear the Good News of the Gospel, that is, unfortunately, not the purpose of this letter. What I have to share with you today relates to criticism that you have recently heard about Gospel for Asia by several former staff members.
In June of 2014, we received a letter from 37 former employees outlining some concerns they had about the organization. After receiving their letter, our first reaction was to consider each of the charges made against us, asking God to show us where we may have been in error. With a desire to seek reconciliation with each person, we reached out one by one to all who signed the letter. Unfortunately, we were only given the opportunity to reconcile with one of the signatories. But we praise God for bringing about reconciliation with that one!
After unsuccessfully trying to seek biblical reconciliation with the entire group, our board designated one member to conduct a formal inquiry into the outlined complaints. To ensure a fair and unbiased process, I along with my wife, son and members of the board, recused ourselves from participating in the investigation. At the same time, our leadership team examined our human resources policies and procedures, making improvements wherever possible, and affirmed the freedoms afforded to those called to the work of Gospel for Asia. The board investigation concluded the following:
“We are broken-hearted and repentant that we damaged by our actions and attitudes any believer for whom we had responsibility by relationship.”
“[We] feel that your [the authors of the letter of complaint] other accusations are without foundation in terms of the fulfilling of our call to enlarge the Kingdom of God.“
I want to acknowledge there have been times when I have not communicated with enough grace nor with enough clarity when speaking to members of our staff. It has always been my goal to keep short accounts and ask the Lord each day to show me where I have offended someone, so that I might seek the forgiveness of God and the one I have offended. I am not perfect and thank God that he is gentle with me as I seek to serve him. I will not apologize for the zeal I have for God’s work, but I do sincerely apologize for the times I have been insensitive to those working along side me.
It grieves my heart that this matter has gained outside attention and is now causing distraction from our mission of reaching the people of Asia with the Gospel, and I wanted you to hear directly from me how saddened I am. I am grieved not only for those who have felt it necessary to take such actions against the ministry, but also for the people of Asia who do not currently know our Lord and Savior.
Because I believe that disputes among brothers and sisters in Christ should be handled in a manner that accords with the Scripture, I have not issued a blanket response and have chosen to not respond any further to incoming media requests for comments. We have no desire to carry out a dispute between brothers and sisters in Christ in front of a lost and dying world.
As our financial partner, I want you to know that we take the responsibility of stewarding your resources well with the utmost seriousness. While we cannot publicly disclose all of our financial information to protect the safety of workers on the field, we submit to an independent audit and the review of the Evangelical Council for Financial Accountability.
As I conclude this letter, I want you to know that Gospel for Asia’s motivation has always been to reach as many people as possible in Asia with the Gospel of Jesus Christ and grow in our ability to reflect the character of Christ in our own organization. We want to fulfill our role in carrying out the Great Commission. And we want to reflect God’s love, wisdom and uprightness as we serve in his name.
Regarding those former employees with unresolved concerns, it is my desire to reconcile when possible and disagree in love when necessary, so that we might stand together in our commitment to spreading the Gospel throughout Asia. I hope you will pray for a speedy and godly resolution to this situation. But most of all, I hope you will continue to intercede for the millions in Asia waiting to hear of God’s love for them. May they come to know the One who died for them—and for me.
Please know you are extremely important to the mission of our organization, and I want to invite you to contact me with any further questions or concerns. Be assured that you will be heard.
For those who need the love of Jesus,
K.P. Yohannan

Some comments. On the 37 former staff letter, please recall that it is now over 80 former staff that have raised the concerns. Yohannan said:

Unfortunately, we were only given the opportunity to reconcile with one of the signatories. But we praise God for bringing about reconciliation with that one!

GFA has had the opportunity to meet but hasn’t. Please see the former staff website for a history of this dispute between GFA and the former staff.
From the letter:

Because I believe that disputes among brothers and sisters in Christ should be handled in a manner that accords with the Scripture, I have not issued a blanket response and have chosen to not respond any further to incoming media requests for comments. We have no desire to carry out a dispute between brothers and sisters in Christ in front of a lost and dying world.
As our financial partner, I want you to know that we take the responsibility of stewarding your resources well with the utmost seriousness. While we cannot publicly disclose all of our financial information to protect the safety of workers on the field, we submit to an independent audit and the review of the Evangelical Council for Financial Accountability.

I and others have gone to GFA prior to publication on various matters and they have not replied. Furthermore, the financial matters are not Matthew 18 issues but rather part of accountability as a non-profit organization and public charity. The rest of this is a non-answer and another great illustration of how the ECFA isn’t working for donors.
Basically the message is GFA is too busy winning millions to Jesus and we can’t be bothered with petty questions. This is the same K.P. Yohannan that posted the following on the GFA website:

And if you hear something about Gospel for Asia that doesn’t sound right, would you please contact us—via email or phone—and let us know? Whenever there are accusations, we seek to immediately respond. We don’t walk away or cover it up. Most often, these are simply rumors or misunderstandings. And if we are wrong, we are happy for the opportunity to repent and make things right. We desire to walk in the light with the Lord and with our brothers and sisters.

The fact is GFA is not answering questions or responding, immediately or otherwise. With this new letter, K.P. Yohannan continues the spin.

More Questions for Gospel for Asia About 2013 Spending and Funds Unaccounted For

It has been nearly a week since I posted auditor Jason Watkins analysis of publicly available records of Gospel for Asia’s spending in 2012.  I sent the information to Gospel for Asia’s CEO, K.P. Yohannan, and COO, David Carroll as well as the president of the Evangelical Council for Financial Accountability Dan Busby. I asked them to provide information which would contradict Watkins’ findings. No reply.
Today, I want to post Watkins’ analysis of the spending in 2013. Over just these two years, if Watkins is correct, $90 million that GFA affiliates report as contributions to GFA in India do not show up in Indian reports (see both posts).
GFA Pie Chart 2013 F2
This is a similar break down as the 2012 chart.
I want to add that GFA may have some explanation for where the $47 million is. It may be that they give it away to other organizations in India (which might be a problem, see this report). If GFA ever responds with additional information, Watkins and I will adjust the analysis and other posts.
For those who are disturbed by these reports, I want to say that this analysis was done with publicly available records. These records are required by various governments and watchdog groups to keep organizations accountable. An examination of those records has led to this analysis and others I have previously published. I have in good faith asked GFA for explanation or additional information. However, COO David Carroll told me in May he would no longer answer my questions.
GFA stopped responding to my requests on May 7. For nearly eight weeks, GFA has remained silent as report after report has been published. To staff, leaders admitted requiring students to carrying cash to India, and told them it wasn’t illegal. GFA said their audit firm, Bland Garvey, said what they did was fine and legal. Then, they acknowledged that they have retained lawyers. However, at no time has GFA commented about why they violated their own financial integrity promises and possibly U.S. law to get hundreds of thousands of undeclared U.S. dollars to India.
My sources inside GFA tell me that some students have left the School of Discipleship over these issues and others including the conflicting stories over Believers’ Church bishops kissing His Eminence the Most Reverend Metropolitan K.P. Yohannan’s ring at ordination.
On the GFA website, CEO Yohannan promises*:

And if you hear something about Gospel for Asia that doesn’t sound right, would you please contact us—via email or phone—and let us know? Whenever there are accusations, we seek to immediately respond. We don’t walk away or cover it up. Most often, these are simply rumors or misunderstandings. And if we are wrong, we are happy for the opportunity to repent and make things right. We desire to walk in the light with the Lord and with our brothers and sisters.

I have been contacting you since May with no answers. Rev. Yohannan, you walked away 55 days ago.
*This was written before the recent controversies. There have been other issues over the years I haven’t begun to examine.

An Auditor Raises Questions About Gospel for Asia's Promises, Spending and Unaccounted For Donations

I have been raising concerns for weeks about Gospel for Asia’s use of students to carry undeclared cash to India and unreported donations in India.  GFA remains silent and the Evangelical Council for Financial Accountability appears to be disinterested in the evidence submitted. Neither organization responded to my request for comment and information about this post.
On the other hand, I regularly receive emails from former GFA donors and supporters who have taken the information very seriously and have contacted GFA. Thus far, no donor who has contacted me has expressed satisfaction with GFA’s answers. Also, I was recently contacted by Jason Watkins, a former auditor with a Big 4 accounting firm who did a detailed analysis of GFA’s finances using information publicly available from around the world. I will post more of his material in coming days, but for today, I want to post an image depicting Watkins’ analysis of where GFA funds were spent in 2012. See below:
GFA Pie Chart 2012
I have posted information which addresses some of these issues, but this image brings 2012 together in one place.*
Jason had this to say about the chart:

The data from the FC-6 Forms for the 4 GFA NGO’s (Gospel For Asia-India, Believers Church, Love India, and Last Hope) were obtained and converted to US dollars. The amounts reported as received from foreign (non-Indian) countries were reconciled to the amounts reported as sent by Gospel For Asia, Inc. (US), Gospel For Asia-Canada, Gospel For Asia-UK, et al. This reconciliation shows that nearly half of the money sent from the west was not reported as received by GFA in India. That money is not accounted for. That is, of the $95 million that was spent by all entities, $45 million was not reported and $50 million was reported in India.
Further, of the foreign $50 million that was reported as received in India, an analysis of the ways that money was spent was performed. This analysis segregated and identified the specific expense categories (water wells, children, women, disaster relief, missionaries, administrative expenses, et al) to show how much was actually spent for the purposes indicated.
The amounts on the pie chart are a sum of the spending categories [called ‘utilised’ on the FC-6] reported in India on the 4 GFA NGO’s FC-6 forms, and then dividing each spending category by the sum of the spending of all GFA entities ($95 million).

The Indian government requires completion of the FC-6 form by registered charities. GFA has completed those forms but, as Watkins points out, the GFA affiliates around the world report sending more funds than the FC-6 forms show as received.
Watkins found reason to question several of GFA’s signature claims:

Gospel For Asia (GFA) solicits and collects over $90 million per year from trusting donors by using the following claims:

A detailed analysis of the actual spending by Gospel For Asia in 2012 reveals

  • 47% of the money ($45 million) is missing and unaccounted for. This was money donated by citizens of the US, Canada, UK, and other western countries. This money has not been recorded as received by the four Indian NGO’s (Gospel For Asia-India, Believers Church, Love India, and Last Hope) according to the FC-6 forms filed with the Indian Ministry of Home Affairs. If there are other NGOs directed by GFA, then GFA should reveal this.

  • 21% of the money ($20 million) was spent on administrative overhead in the west (12%) and administrative overhead in the field (9%).

  • Only 31% went towards charitable expenses, and only 12% actually reached the needy. These are the items that are highly promoted as uses for your donations (water wells, disaster relief, humanitarian outreach, women, children, and missionaries).

  • GFA spent $0 on adult literacy and poverty and yet this is a huge promotional item.

I have asked GFA several times for information regarding these matters. However, GFA told me that the organization would answer no more questions. Regarding the claims of 100% going to the field, I have indicated before that much of the money is on the field, but it is sitting in banks.
Perhaps this is case of bad reporting on the part of GFA. Maybe there is some other explanation. I have acknowledged in the past that I am not an auditor and have been open from the beginning of my research to any information provided by GFA. However, when an experienced auditor examines the publicly available documents and comes away with these findings, I think it is past time for GFA to address these matters.
I have additional analyses to report and plan to do so in the coming days.
*Sources: Forms FC-6 filed by Gospel For Asia-India, Believers Church, Love India, and Last Hope with Indian Ministry of Home Affairs; Audited Financial Statements of Gospel For Asia, Inc. (TX Corp); Gospel For Asia-Canada, Forms T-3010 filed by Gospel For Asia with Canada Revenue Agency (CRA); Unaudited Financial Statements of Gospel For Asia (Australia) Inc. filed with Australia Charities Regulation Commission (ACNC); Audited Financial Statements of Gospel For Asia (UK) Ltd. filed with the UK Charity Commission; and other online inquiries. Local currencies were converted to USD using exchange rates at for the relevant reporting periods.