According to Gospel for Asia's Indian Website the Bridge of Hope Program Doesn't Accept Foreign Sponsorships

In May of this year, I pointed out that Gospel for Asia requests $35/month to sponsor a child in Asia through the Bridge of Hope program but much less per month in India. Thanks to an alert reader, I was made aware that the Indian website for the Bridge of Hope program tells potential Indian donors that Bridge of Hope doesn’t accept foreign sponsors.
BridgeofHopeIndia
 
According to the Indian website, Bridge of Hope is a program of Believers’ Church. The American website doesn’t mention Believers’ Church and advertises the program as Gospel for Asia’s Bridge of Hope. Gospel for Asia’s Indian website hardly mentions Bridge of Hope. GFA-US sent around $30 million to Believers’ Church and two other K.P. Yohannan controlled NGOs in 2013. Ultimately, some of those funds support the Bridge of Hope program in India. At least that is what GFA tells donors in the U.S.
GFA-U.S. says donors are sponsoring children through Bridge of Hope. Bridge of Hope in India is managed by Believers’ Church which tells donors in India that sponsorship is not accepted from outside of India. Which message is correct?
Add this question to the growing list that GFA isn’t answering.
 

Gospel for Asia and Evangelical Council for Financial Accountability's Standard 4

ecfa sealYesterday, I wrote that Gospel for Asia may be in conflict with IRS guidelines regarding granting U.S. tax exempt donations to foreign entities. Today, I want to compare publicly available information about GFA to the Evangelical Council for Financial Accountability’s Guideline Four. In this post, I am specifically interested in the ECFA requirements for members who send money to foreign organizations and affiliates.
ECFA members are required to adhere to the following guidelines:

International grant-making.  U.S. tax law does not prohibit the making of grants by a U.S. tax-exempt organization to recipients in other countries if they further the U.S. organization’s tax-exempt purposes. However, the IRS has articulated some parameters as to when contributions may or may not be deductible for tax purposes, if they are made to a U.S. charity and subsequently distributed in the form of a grant to a foreign recipient.
The reason for IRS scrutiny of such grants is because only donations to a U.S. tax-exempt organization are deductible as charitable contributions. Contributions by a U.S. taxpayer to a foreign organization are not tax-deductible.
A U.S. charity may not act merely as a conduit of funds for a foreign recipient. This would result in treating these indirect contributions to a foreign organization as tax-deductible contributions, something that would not be allowed if the funds were made directly to the foreign entity.
However, if a grant is made by a U.S. charity to further its exempt purposes, and if the grant funds are clearly under the control and discretion of the U.S. charity rather than the donor, it is unlikely that the IRS will challenge the deductibility of the gift.

The issue of “discretion and control” is what I raised yesterday. GFA-US did not disclose millions of dollars of U.S. donor money given to Believers’ Church, Love India Ministry and Last Hour Ministry in the 2013 annual audit. Instead, GFA-US claimed that $58.5 million went to GFA-India. However, GFA-India only disclosed $6.5 million in donations from the United States. Even if donations from GFA-US to the other three NGOs were listed in the 2013 audit, $30.5 million dollars still went unreported in India in 2013 (see this article for the breakdown).

The real donees for about $28 million dollars from U.S. donors are Believers’ Church, Love India Ministry and Last Hour Ministry. According to GFA-US, Believers’ Church is a separate organization legally. Recently, David Carroll told Christian Today:

GFA’s Chief Operating Officer David Carroll told Christian Today that it was important to understand that GFA India and Believers Church were separate entities from Gospel for Asia USA.

Carroll said that the Indian GFA and Believers’ Church are responsible for dispersing the funds:

“Though Gospel for Asia India and Believers Church is responsible for dispersing the funds, they know the requests of the donors for the specific designations the money was given for and they are fastidious about documenting the disbursement of donor funds. The donations go where they have been designated.”

It may be true that the donations go where the donors want, but then again they may not. GFA has given the public reasons to question. David Carroll wants us to take his word that GFA-India and Believers’ Church spend the money in keeping with donor intent. However, when auditor Jason Watkins, pastor and former donor Bruce Morrison, and I analysed the public reports of GFA-India’s and Believers’ Church’s spending in India, we couldn’t find millions of dollars GFA-US said was sent to India. The reports of what was received in India don’t match the claims of giving in the U.S. In response to questions about the discrepancy, GFA has been silent. Furthermore, an Indian tax court recently wrote that GFA used funds for reasons not in keeping with the intended purpose. Without a plausible accounting of millions of donor dollars, why should the donor public believe that GFA-India and BC are spending the funds they do report in keeping with donor intent?

The guidelines continue:

Organizations may seek professional counsel concerning operations that result in grants to foreign recipients. Various rulings and tax cases stipulate certain characteristics in evaluating whether grants to foreign recipients are proper, exempt-purpose expenditures of the U.S. charity and, therefore, if any supporting gifts actually are deductible by donors of those funds.

Impact of international operations on the financial statements.  It is important for organizations to properly control, adequately account for, responsibly audit, and fully disclose in their financial statements the nature and scope of their operations, both within the U.S. and internationally. Organizations and their auditors should consider the impact of worldwide operations on the scope of the audit, and the financial statements should report on all organizational assets, liabilities, revenue, and expenses.

This guideline is not being met. The 2012 and 2013 audits do not disclose funds given to Believers’ Church, Love India Ministry and Last Hour Ministry. The amount claimed to be given to GFA-India by GFA-US comes nowhere close to matching up with what is reported in India. Furthermore, GFA’s audit doesn’t include $14 million USD given by Canadians, supposedly to India, but not reported in India. According to GFA’s COO David Carroll, Canadian funds are lumped in with the U.S. funds and reported together. However, that makes the discrepancy $14 million greater since GFA-India does not report a penny coming from Canada.

The publicly available audit provided by GFA does not fully disclose their operations within the U.S. and internationally. This has been true for years and yet GFA has used the ECFA seal of approval to claim financial health and integrity. As recently as June 10, the ECFA told Christian Today:

Regarding apparent financial discrepancies, it said: “There are certain foreign NGOs that include ‘Gospel for Asia’ in their name. The data of those NGOs is not consolidated with that of Gospel for Asia (US) for financial statements purposes.”

Why not? ECFA’s guideline four certainly appears to require consolidated reports.

It [ECFA] concluded: “Gospel for Asia is in full compliance with ECFA in requiring our members to provide a copy of its current financial statements upon written request and other disclosures as the law may require. The organisation has gone beyond what the law requires by submitting to ECFA’s accreditation process.”

Is GFA-US (and ECFA) really going to claim that these GFA NGOs are not part of their international operations? If so, then how can GFA-US claim that they exercise “discretion and control” over the donations given by U.S. tax payers? If GFA-India and Believers’ Church are so autonomous that they are not part of ECFA-required financial reporting, then how can U.S. donors be confident that GFA-US has sufficient “discretion and control” to make sure those dollars are going where donors specify?  This question is especially relevant since the reports filed by the Indian recipients of U.S. donations to GFA don’t match what GFA claims they send to India.

Back to the guidelines:

To be “unqualified” or “clean,” an independent auditor’s report must reflect no restriction on the scope of the audit.

The reach of an organization extends to activities conducted under its control (internationally) when expenditures are made to further its exempt purposes to compensate workers, pay business expenses, provide benevolence to the poor and needy, or to make exempt-purpose grants.

These “exempt purposes” are among the purposes reported in India for funds sent by GFA in Texas.

The guidelines continue:

In order for financial statements to be in conformity with generally accepted accounting principles (GAAP), they must accurately portray the full range of the organization’s operations internationally.

A review of GFA’s 2012 and 2013 audits makes it clear that GFA is in violation of this statement. The financial status of the Indian affiliate (what GFA-India is called in the 2013 financial statement) is not reported, nor are donations to Believers’ Church, Love India Ministry and Last Hour Ministry reported in the audit. I should add that the funds smurfed to India via student groups illegally carrying money to India without being declared in the United States is not referred to in the 2012 and 2013 audits.

Guideline 4 continues:

The FASB Accounting Standards Codification 958-205 (Topic 205, “Presentation of Financial Statements”) sets forth that such statements must focus on the organization as a whole, including its total assets, liabilities, net assets, revenue, expenses, and changes in net assets. In addition, ASC-810 (Topic 810, “Consolidation”) helps guide a reporting organization as to when it must consolidate another not-for-profit organization in which it has a controlling financial interest.

Significant granting activities should be properly disclosed in an organization’s financial statements, including a description of the nature and purpose of the grants and the grant administration policies.

I think $20.6 million to Believers’ Church, $3.6 million to Last Hour Ministry and $3.6 million to Love India Ministry would have to be considered “significant granting activity.” These are not disclosed in the financial audit done by Bland Garvey; and yet ECFA declares GFA to be in compliance.

Guideline 4 continues:

Grant administration policies should be well-developed and approved by the governing board, while adaptable to a wide range of circumstances. The following are possible controls and accountability measures:

  1. Written progress reports
  2. Required accounting or financial statements
  3. Required internal or independent audits and inspections
  4. On-site program inspections by grantor personnel
  5. Retaining discretion as to when funds will be remitted based on administration policies and grant agreements, including the policy and practice of refusing conditional or earmarked gifts that create an obligation to remit the funds immediately
  6. Adequate oversight (supervision) and review (program evaluation) or compliance with administration policies by the governing board and/or the organization’s independent auditors

Conformity with applicable laws and regulations.  Standard 4 establishes the guideline that ECFA accredited organizations shall use resources in conformity with applicable laws and regulations. The standard provides a caveat that biblical mandates may be taken into account when considering conformity with laws and regulations. In select situations, an accredited organization may feel compelled to take actions that are in conflict with certain laws, i.e., with respect to religious freedoms and carrying out the Great Commission.

The ECFA requires the board and auditors to maintain oversight sufficient to insure that the organizations policies are being carried out. The public doesn’t know why millions of dollars don’t show up in Indian reports. However, it is known and now admitted that GFA violated its own policies regarding cash transfers to India via smuggling cash via students. GFA claims to only send money to foreign destinations via bank wire. For some undisclosed period of time an undisclosed sum of cash was sent to India without declaring the cash to U.S. or India customs. ECFA and GFA want all of that to go away by saying they won’t do it again.
What donors should understand is that GFA was a member in good standing the entire time they violated their own and ECFA’s standards. They remain a member in good standing with no consequences at all to that standing.
For ECFA purposes only, the last section may give GFA some wiggle room to keep secrets about reporting funds received in India. If GFA-India isn’t reporting all of the income that GFA-US claims is going there (we already know an Indian court has asserted that all the funds are not being used for the intended purposes), this would be a violation of Indian law. The lack of reporting of Canada as a source of $14 million USD appears to be a violation of Indian law. GFA might claim that the lack of reporting was due to protecting missionaries in some way. This seems to be the GFA response line but I have heard no plausible explanation about how non-disclosure of some funds but not others protects anyone’s safety.
 

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.

bcmch
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.
 
 
 

Gospel for Asia Reports One Thing in American Audit, Another in Indian Reports

In addition to the usual income and expenses data, Gospel for Asia’s audited financial statement discloses related party transactions. As you can see from the image below, the direction of the transaction is from the U.S. to GFA affiliates in Asian countries with 96% going to India. In addition to GFA India, GFA in the U.S. claims contributions to GFA affiliates in Myanmar, Sr Lanka, Bangladesh and Nepal. See below:
GFA Related Party Transactions 2013GFA reports contributions to five related non-profits. However, in the Indian FC-6 report, three other charities — Believers’ Church, Love India Ministries, and Last Hour Ministries — report receiving contributions from GFA in America. In the audited financial statement above, GFA reports to Americans that the organization gave $58,542,900 to GFA India in calendar year 2013. However, in the FC-6 form filed to the Indian government, GFA – India reported that much less than $58 million was received. Just from the U.S., GFA – India reported that they received INR 404,638,271 which converts to $9,170,270 million USD during the period between April 1, 2013 and March 31, 2014 (see line 5 below).*
GFA FC6 Countries
GFA said in the audited financial statement over $58 million was sent to GFA India, but GFA in India reported only a little over $9 million being received (actually more like $6 million, see the last note below).**** So where is the rest of the money?
As I reported in a prior post, GFA in America also sent money to at least three other charities in India: Believers’ Church (INR 909,041,794 = $20,601,500), Love India Ministries (INR 162173900 = $3,675,330) and Last Hour Ministries (INR 161084820 = $3,650,650) (click the links for their FC-6 forms).  Looking at what came from the United States to all four of these entities, the total is $37,097,750 which still does not get us to the $58 million GFA claims came from the U.S.** It is possible that GFA – U.S. contributes to other ministries in India that have not been disclosed or discovered yet. However, just taking these reports at face value (what GFA says in the audited statement and what GFA tells the Indian government, there appears to be a significant discrepancy.
It is worth asking what Love India Ministries and Last Hour Ministries do. I can’t find a viable web presence for either entity and as far as I can determine, GFA does not mention them in their materials. They may be shell companies operating in name only, much like the 12 limited liability corporations in Texas mentioned in the audited financial statement which exist just to transfer money to the field.***
Thus, at least two problems emerge for GFA’s credibility. One, GFA claimed in the audited financial statement that it only contributed to “five related non-profit organizations.” However, GFA in the U.S. uses 12 LLCs to send money to at least three additional registered charities in India (Believers’ Church, Love India Ministries and Last Hour Ministries) which are not disclosed in the audited financial statement. Two, the amounts GFA says they send to GFA in India comes nowhere close to matching what GFA – India reports to the Indian government.
Thus far, GFA has remained silent in the face of questions regarding cash smurfing to India, video of Believers’ Church bishops bowing and kissing the ring of GFA president K.P. Yohannan in contradiction to Yohannan’s denials of the ritual, discrepancies in Bridge of Hope giving requests and spending, and cash hoarding in Indian bank accounts. These discrepancies being reported today now call into question the accuracy of the American audited financial statement. Silence may be a good PR strategy but it seems ill-suited for a Christian ministry.
 
*It seems very unlikely that the different reporting years explains the $ million difference. Both methods of accounting cover 12 month periods which report consistent monthly giving totals year over year.
**Contributions to GFA-India, Believers’ Church, Love India Ministries and Last Hour Ministries from all foreign sources (including interest on foreign contributions) totaled $54, 550,683 for fiscal year ending March 31, 2014, still less than the $58 million to India reported on the audited financial statement.
***As an aside, it is worth asking again why sending cash to India in student backpacks was ever done. GFA told students it is a way to get cash into India. As one can see from the financial statement, GFA set up 12 LLCs to transfer money, and even transferred $9 million at one point just to get better interest payments. There appears to be no problem getting money back and forth from India. 
****I remembered after doing the post that India’s FC-6 forms require a charity to record when the contributions are received. Thus, I was able to discern the amount sent during the calendar year 2013 but looking at the reports for the fiscal years 2012-2013 and 2013-2014. The situation is actually worse than I first reported. GFA – India reported that they received only $6 million in calendar year 2013. The American audit says GFA U.S. sent $58 million to GFA India in the calendar year but GFA India only reported $6 million in the same time span.

How Much Does it Really Cost to Sponsor a Child with Gospel for Asia?

Yesterday, I pointed out that the expenditure of foreign funds by GFA in the fiscal year ending on March 31, 2014 for the support of children enrolled in the Bridge of Hope program seemed quite low, estimated at around $105 per year. Today, I want to point out that GFA’s request for child sponsorship in India is about one-third of what it is here in the U.S. and that the actual costs are even lower than that.
On the U.S. website, GFA requests $35/month to sponsor a child:

It only takes $35 a month to give a child everything they need—school supplies, a daily meal, medical checkups and more—to attend a Bridge of Hope Center. 100% of your sponsorship is sent to the field to support your child.

However, on the GFA/Believers’ Church Indian website, the cost is INR 800/month or about $12.50 in U.S. dollars per month. That’s quite a discount. The sponsorship page promises:

Your sponsorship of Rs. 800 per month provides [child’s name]:

  • An Education
  • A nutritious meal each day
  • A yearly medical checkup
  • Basic school & hygiene needs

I have also seen GFA budget documents which tell a more surprising story.* The actual cost during fiscal year ending 2014 to support one child in a GFA Bridge of Hope center in India was just under INR 500 or around $8.20 per month per child. This paid for the administration of the program, food purchases, and all child services. In fact, the actual items given to each child (school supplies, clothes, hygiene supplies and gifts) only cost INR 140 per child or $2.20 per month.
At that rate, Americans who send $35/month to GFA for a child sponsorship could actually support 4 children. Or GFA could keep the excess in a bank and draw interest on the balance as they appear to be doing. As I noted yesterday, GFA spent over $6 million in foreign contributions on Bridge of Hope expenses in FYE 2014 but had in the neighborhood of $25 million designated for “the welfare of children” sitting in a bank drawing interest at the same time.
GFA has to report that interest (the banks do as well) and all four GFA controlled organizations accumulated $4.2 million on the money in savings accounts by the end of FY 2014.
GFA says “100% of your sponsorship is sent to the field to support your child.” Perhaps this statement should be reworded. The money is sent to the field but a lot of it apparently ends up in a bank on the field.
It is past time for GFA to end the silence and address this matter as well as others which have come out in recent weeks.
 
*I have the documents but don’t have permission to publish them.

How Gospel for Asia in India Spent Foreign Contributions in FYE 2014

Each year registered charities in India are required by law to disclose how they spend foreign contributions. Out of curiosity, I examined Gospel for Asia’s FC-6 report for the fiscal year that ended on March 31, 2014 (most recent data available). Below is a chart that combines the money spent from contributions from GFA (U.S., Germany, Australia, New Zealand, etc.) in U.S. dollars to GFA-India, Believers’ Church, Love India Ministries and Last Hour Ministries.* GFA also sends funds to affiliates in Nepal, Myanmar, Sri Lanka, and Bangladesh. According to GFA’s financial statement ending in 2013, India receives 96% of the contributions from the U.S.

GFA FYE 2014 Foreign expendThe largest expense is construction and administration of Believers’ Church Medical College Hospital.  According the hospital website, “Believers Church Medical College Hospital is a healthcare project of Believers Church. The Church is dynamically involved in various nation-building social and educational projects, healthcare initiatives, charitable activities, community development programs, rehabilitation projects and relief works. Dr. K.P. Yohannan, Metropolitan of Believers Church is the patron of the hospital and Dr. George Chandy is leading the project.”
About $1.9 million for the BCMCH came from GFA affiliates in Germany, Australia, and the UK, with the rest coming from GFA in the U.S.
If one includes the hospital, two-thirds of the funds — just over $35 million — are spent on support for ministries of Believers’ Church in India. At least one pastor recently announced that he gave up his support for GFA because he learned that he was really supporting a church he didn’t feel comfortable supporting.

A prominent expense is for welfare of children which includes school fees, food, and funding for the Bridge of Hope program.  According to GFA’s most recent financial statement, they claim that 60,000 children are enrolled in the BoH program.

That works out to only $105 per child per year. 

According to the forms filed with the Indian government, there is a combined balance of just over $23.5 million designated for “welfare of children” sitting in GFA-related accounts. I cannot understand why so much money is sitting in accounts when GFA claims the need is so great (and I have no reason to doubt that the need is great).

GFA promises that “Gospel for Asia sends 100 percent of the money you donate for work on the mission field to the field. Nothing is taken out for administrative expenses.” While that may be true for those working in administration in the U.S., it is not true for GFA, Believers’ Church, Love India Ministries, and Last Hour Ministries.

As I noted in a prior post, GFA has stopped replying to my questions. However, I extend an ongoing invitation to correct anything I write which they believe to be incorrect. There is a link in the footnote below if readers want to check these figures, and I am open to any additional evidence.

*These reports are available online (enter year and the state of Kerala). These four charities were chosen because they all received money from Gospel for Asia’s Texas organizations. To see pdfs of each page, click the links: Gospel for Asia, Believers’ Church, Last Hour Ministries, Love India Ministries. Historical exchange rates can be found at Oanda.com.

Gospel for Asia's K.P. Yohannan and the Ring Kissing Ritual

In one of my early communications with Gospel for Asia’s COO David Carroll I asked:

Can you confirm that the reason GFA organizes as an episcopal type church is related to Indian law. I have been told  that Indian law requires GFA to register as a church and assume a governance structure similar to the officially recognized Catholic Church and the United Church of India.  That means an episcopal structure (with bishops, etc.) is required.  Thus KP Yohannan is officially the Metropolitan (archbishop) of the Believers Church.  Is this why allegiance to KP Yohannan and kissing his ring is involved?

Carroll answered: 

In regard to Gospel for Asia’s structure, while we are thoroughly evangelical, our organization and church structure is specific and unique to the areas where we work most heavily. Additionally, K.P. Yohannan’s title is understood in the countries where we work to refer to the senior leader of the organization.  In regard to your question about kissing K.P.’s ring, I haven’t seen it, nor am I aware, that it has ever happened. 

On ring kissing, David Carroll needs to see this video:
[youtube]https://youtu.be/rfHoh6xMEkM[/youtube]
The man seated is K.P. Yohannan and the men coming forward are being ordained into the Believers’ Church. They very clearly are kissing Yohannan’s hand, and at times, it seems clear that they are kissing his ring.
The allegations that GFA and Believers’ Church have evolved from an evangelical ministry to a self-contained episcopal type denomination have dogged GFA for about a decade. This video was taken at an ordination service. According to my source, the service took place in 2009 in India at one of the Believers’ Church seminaries.
One former leader in India told me that the pastors were taught several years ago to kiss Yohannan’s ring, which has the Believers’ Church emblem on it. However, many felt awkward with practice and the leaders revised the ritual to include bowing low before Yohannan before he touched a person’s forehead with his signet ring. In any case, these rituals seem to place significant emphasis on allegiance to the Metropolitan. 
As recently as April of this year, Yohannan denied remembering it. In a staff meeting, in response to a question about it, Yohannan said:

Did anybody ever kiss my hand or my ring? In memory I cannot ever recall I allowed it to happen or if they did it. Because we never teach it. We never promote it. That is not our doctrine, I am not a god, anything, but if people who talk about it and say this, they saw it, what can I do.
and then…
What have I done to you or to anyone here to promote me? When I took the ring on my hand, as God Almighty my witness, I was going to a death chamber. I never asked anyone to kiss my ring, I never allowed it to happen. We never teach it, we never promote it.
The audio is hard to make out but the first quote above is first on the audio followed by the second quote.
ring-kissing1-cropped
Of course, none of this means that Gospel for Asia is ineffective in ministry to the poor or in service to others. However, the practice of structuring cash transfers to India in ways which evade detection by customs officials and now the double talk on their ecclesiastical practices raises many questions about the organization’s other claims. GFA has asked for and received a significant exception to financial reporting requirements from the Evangelical Council for Financial Accountability. Prominent pastors like Francis Chan claim that GFA’s practices are clean. However, perhaps GFA should respond to these recent concerns with increased transparency rather than silence as they have in the past two weeks.

Money Travels With the Passengers on Gospel for Asia Mission Trips to India

Cash
Image courtesy of sheelamohan at FreeDigitalPhotos.net

Gospel for Asia sponsors frequent “vision trips” to India. These trips help inspire donors and prospective ministry workers to give time and money to the work of GFA. In Texas, GFA runs a School of Discipleship and the students at the school often go as a group to India as a part of their work. According to some former GFA travelers, they pack more than cameras and a toothbrush.
For over two years, some GFA travelers to India have been packing envelopes of cash designed to be taken into India and given unopened to GFA headquarters in Kerala, India.  According to my sources, GFA staff in Texas have on multiple occasions given GFA travelers sealed envelopes filled with cash and said that the envelope contained $4500. The travelers — who were traveling together in groups of various sizes — were told the figure of $4500 was designed to avoid the need to declare the cash in India. Amounts of $5000 or more must be declared upon arrival. According to federal law, any amount of cash may be taken out of the country, but amounts of $10,000 or more must be declared when leaving or entering the U.S. According to my sources, the GFA groups were carrying far more than $10,000 per trip.
Over the last several days, I have spoken to five GFA travelers* who carried money to India in this manner and have examined GFA source information which described the practice.  The sources said that most if not all members of their groups carried the envelopes filled with $4500. For instance, a group of ten people carried $45,000. I asked GFA COO David Carroll for comment but he has not replied.
Pushing the Envelope
One individual told me that a GFA leader told a group of travelers that taxes were high in India and by taking undeclared cash, the ministry would benefit. According to all sources, each individual in the GFA groups received a sealed envelope from GFA leaders in Texas. I was told that one group had ten people carrying cash ($45,000 at one time) and another source said there were 30 travelers in a group (a maximum of $135,000). The travelers were told that each package contained $4500 and that each member of the group would turn in the envelope to a GFA leader in Kerala, India. The money did not belong to the travelers and was not to be used for expenses. The envelopes were to remain sealed and turned over to a GFA leader at headquarters or a Synod office for the Believers Church. Some specifically named Siny Punnose, who works in finance for GFA in India. Some groups consisted of students, some of ministry partners, and at times, pastors have been asked to carry funds.
All sources felt odd about taking the money. One person said fear of losing it or having it stolen was a constant preoccupation. They worried they were doing something that didn’t sound right. Even though the leaders assured them that the practice was fine, it still didn’t seem right.
And, in fact, the travelers may have been right to worry.
Currency Structuring
One may leave or enter the United States with any amount of cash. However, a person who has $10,000 or more must declare it on a form designed by Customs and Border Protection when leaving or entering the U.S. As a recent CBP press release says, one may not split it up and have others carry it for you. In this case, GFA asked the travelers to carry much more than the $10,000 limit in total.

If travelers have someone else carry the currency or monetary instrument for them, they must file a currency report for the entire amount with CBP.  Failure to report may result in seizure of the currency and/or arrest.

Another CBP press release tells of an Italian man who attempted to come into the country with more than $10k along with “co-travelers.”

During a secondary inspection, the man, who arrived from Italy, reported possessing $11,700. It was later discovered that the man had given money to two co-travelers in order to evade currency reporting requirements, an illegal practice known as currency structuring. In total the cash added up to $24,644. CBP officers seized the money, issued the man a $1,000 penalty, and then returned the remaining cash back to the man.

The reporting requirements apply to travelers leaving and entering the country.

International travelers who arrive or depart the United States in possession of more than $10,000 or equivalent foreign currency are required to report all currency to CBP officers and complete a Treasury Department Financial Crimes Enforcement Network (FinCEN) form. (emphasis added)

Federal law appears to forbid such undeclared money moves without declaration. None of my sources report any forms filed. Note that the relevant federal law forbids aiding, commanding, or requesting such moves in the aggregate:

§ 103.23 Reports of transportation of currency or monetary instruments.

(a) Each person who physically transports, mails, or ships, or causes to be physically transported, mailed, or shipped, or attempts to physically transport, mail or ship, or attempts to cause to be physically transported, mailed or shipped, currency or other monetary instruments in an aggregate amount exceeding $10,000 at one time from the United States to any place outside the United States, or into the United States from any place outside the United States, shall make a report thereof. A person is deemed to have caused such transportation, mailing or shipping when he aids, abets, counsels, commands, procures, or requests it to be done by a financial institution or any other person. (emphasis added)
(b) Each person who receives in the U.S. currency or other monetary instruments in an aggregate amount exceeding $10,000 at one time which have been transported, mailed, or shipped to such person from any place outside the United States with respect to which a report has not been filed under paragraph (a) of this section, whether or not required to be filed thereunder, shall make a report thereof, stating the amount, the date of receipt, the form of monetary instruments, and the person from whom received.

I am not an attorney and realize that there may be some unknown facts which make this all fine. However, it seems strange to me. GFA can wire money to India and does so frequently. There are many other ways to get money to the field which can be verified transparently. If these travelers are accurate in their reports, GFA is causing hundreds of thousands of dollars in cash to be transported without declaration. This practice seems risky and fraught with many negatives and potentials for abuse.
I want to repeat that on Tuesday I asked GFA’s David Carroll for comment and explanation.
*All sources spoke on condition of anonymity for fear of retaliation from GFA. None of the people I spoke with are affiliated with the GFA Diaspora.

Gospel for Asia Does Not File a 990 Because It is a Religious Order

Donations to Gospel for Asia are tax deductible but the organization doesn’t file 990 forms because they are a religious order. In response to my question, Gospel for Asia’s COO David Carroll answered as follows:

Also, to understand the level of commitment asked of staff and the ways in which we operate, it is helpful to recognize that we are a “religious order” and not merely a ministry. Religious orders must meet certain criteria according to the Internal Revenue Service. All potential staff members are fully briefed on these requirements, including a commitment to “live under a strict set of rules requiring moral and spiritual self-sacrifice and dedication to the goals of the organization.” (IRS Rev. Proc. 91-20, 1991-1 C.B. 524, Sec. 3). The IRS also stipulates that employees “make a long-term commitment to the organization (normally more than two years).”
In the spectra of religious orders, Gospel for Asia would likely afford the highest level of independence and freedom from leadership interference in personal decisions. As a religious order, Gospel for Asia is exempt by the IRS from having to file an annual Form 990. However, it’s worth noting that being a religious order imposes a very modest compensation scale on our ministry.

Based on the following description, I thought the group was a 501(c)3 organization required to report on IRS 990 forms.

GFA is a well-established international mission organization deeply committed to seeing lives and communities transformed through God’s Word and compassion. We are a bridge and servant of the Church to fulfill the Great Commission of our Lord by transforming lives and communities through Christ’s love among the most unreached in our generation. We are a movement dedicated to glorifying the name of Jesus Christ and to proclaiming His grace and love to those who desperately need to hear it.

On the Frequently Asked Questions page, the religious order question is addressed:

I hear GFA is a religious order. What does that mean?
GFA is officially recognized in the United States by the IRS as a protestant/evangelical religious order, much like Wycliffe, Open Doors, U.S. Center for World Mission, Cru (Campus Crusade for Christ), Operation Mobilization, Living Waters and other Christian ministries. That means GFA has the following characteristics defined by government law:

  • Members of the organization normally live together as part of a community and are held to a higher level of moral and spiritual discipline than that required of lay church members.
  • Members of the organization work or serve full-time on behalf of the religious, educational, or charitable goals of the organization.
  • Members of the organization participate regularly in activities such as public or private prayer, religious study, teaching, care of the aging, missionary work, or church reform or renewal.
The result is that the information normally contained on a 990 isn’t easily available.
One reason I wondered about the 990 form is because I am trying to get some understanding of this massive organization. The group claims it must keep the financial information private because of concerns over persecution. However, I have learned that much of the information about GFA’s work in India is reported yearly to the Indian government. The information is also available to the public (see this post for instance).
Stay tuned…