Is Gospel for Asia's Indian Corpus Fund One Reason Why ECFA Terminated GFA's Membership?

One of the first things I noticed when I first started investigating Gospel for Asia’s finances in India was the corpus fund set up for the Indian organizations (i.e., GFA-India, Believers’ Church, Love India Ministries, & Last Hour Ministries). When I examined Indian records (FC-6 reports), I saw millions in U.S. dollars used to fund these accounts. A corpus fund is a “permanent fund generated and kept for basic expenditures needed for administration and survival of the organisation.” (also see this link)
There is nothing wrong with setting up a corpus fund. In India, organizations can set up a fund and use the interest earned for charitable purposes. However, the donations to the fund are not supposed to be used unless the organization’s existence is threatened.
Another important condition is that donations to the corpus fund must be designated for that purpose by the donor, usually in writing. Without designation, donations are not supposed to go to the corpus fund, but rather to the charitable purpose intended by the donor. The evidence I produce here today suggests to me that GFA donor funds have been systematically diverted to the GFA corpus fund apparently without donor designation for that purpose.
First, I have access to reports showing all donations to GFA – United States for years 2004-2008, 2010-2014 (2009 was unavailable from my source). None of those reports show any donations to a corpus fund.
To illustrate, click through this link to see the 2012 report (it is too long to include in the post). All donations are credited to a specific line item and all line items used by GFA are included in this chart of donations (I have redacted the names of staff and the amount received in their support accounts). I cannot find any line item which refers to a corpus fund. None of the reports going back to 2004 have a line item for the designation of donations to a corpus fund.
Now take a look at this chart of GFA contributions prepared by Jason Watkins, a former auditor with a Big 4 accounting firm. This table shows the donor funds sent by GFA to Indian affiliates to establish and maintain corpus funds. I have independently checked the figures in this table.
20092013CorpusFundsGFA
This table also shows the percentage of total giving from GFA -United States to the Indian affiliates. Total corpus fund donations from GFA represents about 35% of all giving from GFA to Indian affiliates since fiscal year 2010.
Where did GFA get the money to give to their Indian affiliates?
Due to GFA’s claim that 100% of donations designated for the field go to the field, I feel sure many donors think that 100% of what they give goes to a missionary or children or disaster relief or some such good cause. However, the Indian records show that GFA leaders have established a financial cushion for Believers’ Church and related organizations in India with over $67 million from GFA in Texas. Diverting donor money to a corpus fund would violate ECFA guidelines and might have figured in ECFA’s vote to terminate GFA’s membership.
In summary, donations toward the corpus fund do not show up on GFA’s comprehensive giving reports. However, in the FC-6 reports in India, millions of dollars in contributions to the corpus funds are listed as coming from GFA in the United States. I ask again where did GFA get that money? Nothing in available reports shows donations earmarked for the corpus fund.

Gospel for Asia Appears to be Saving for a Very Rainy Day

In a recent staff meeting (May 14, 2015), Gospel for Asia leaders told staff that they had $7 million in cash balance in India. Responding to a question from a staffer about why GFA is sitting on so much cash in India, COO David Carroll answered:

That account will tend to build up over the year, it will ebb and it will flow and it will go down as money is spent. Currently, is there 94 million dollars in there or someone asked is there $150 million dollar fund on the field? No, currently the balances from what I understand from India are around 7 million dollars in that particular, those particular accounts. The reason that they are there is because we have to report all foreign contributions that come in. Money will swell and as we spend the money the money will go. We cannot spend the money until we can spend it on the project for which it was designated.

This puzzled me because it seems to contradict the financial contribution reports filed with the Indian government every year. Something isn’t adding up when one compares Carroll’s information to what is filed with the Indian government.  According to the most recent report showing GFA’s use of foreign contributions for the Indian fiscal year ending March 31, 2014, GFA alone had $54,929,800 listed as a cash balance. If you include the other entities that receive money from U.S. based GFA controlled limited liability corporations, the balance swells to $158,165,400.*
GFA and Believers’ Church both receive money from several LLCs with Texas addresses (e.g., see this list). Two other groups do as well: Last Hour Ministry, and Love India Ministry. The image below shows the cash balances for each of those organizations in India. These numbers do not include U.S. operations, which are likewise substantial.
FYE2014CashBalancesGFA
Carroll is correct that funds designated for a particular purpose cannot be used for another purpose and so if GFA receives a lot of money for something that is not needed on the field, then they have to wait until they need it to spend it. The report filed with the Indian government provides a reasonable amount of detail about where funds have been and are designated to be spent (see the entire report here). See below:
gfa2014FYEbalance
Note the red boxes on the right side of this chart. The cash balance GFA reported to the Indian government was (in rupees) 3,288,264,488.79. Using the exchange rate on  March 31, 2014, this converts to $54, 929,800. Similar calculations led to the image above showing over $150 million. Also note that the previous balance was (in rupees) 2,984251885.50. At the March 31, 2013 exchange rate, that converts to $54,601,600 as a cash balance in 2013.
Donors might have a lot of questions after reviewing this information. For instance, what is a Corpus Fund, and why was $21,512,100 sitting in it as of March 31, 2014? It doesn’t appear that any foreign funds were spent on welfare of widows and orphans. There may be perfectly good explanations for all of the questions raised by these reports. However, given GFA’s promises, the massive amounts of money involved, and the other issues identified of late, there is no reason the public and staff shouldn’t ask.
To explore these reports, go to the foreign contributions portal, and then click on the years of interest. All data are not available for 2014-2015 as yet, so click 2013-2014 for the most recent data. Then also click on “Kerala” for the state and hit submit. There you will see all of the charities operating in Kerala. Find Gospel for Asia, Believers’ Church, Love India Ministry, and Last Hour Ministry. Historical exchange rates can be found here.
 
 
*I am using exchange rates from March 31, 2014.