We need to talk about secular humanism.

[ProfessorDavey]

No, the idea of grouping the parishes is unworkable. It would mean each parish relinquishing control of its finances and that would cause a lot of trouble.

No it wouldn't - there are loads of examples of charities where there is a single large charitable organisation with many smaller groupings that are financially independent. All it requires is for donations received by individual parishes to be 'restricted' for use by that parish - happens all the time. And the most obvious example is the RCC - they have just 20-ish diocese charities, none of their local parish churches are separate charities. Yet those local churches operate in a financially independent manner, but need to report to the diocese to generate the overall accounts and annual reporting. Seems to work fine for them.

[jeremyp]

No it wouldn't - there are loads of examples of charities where there is a single large charitable organisation with many smaller groupings that are financially independent. All it requires is for donations received by individual parishes to be 'restricted' for use by that parish - happens all the time. And the most obvious example is the RCC - they have just 20-ish diocese charities, none of their local parish churches are separate charities. Yet those local churches operate in a financially independent manner, but need to report to the diocese to generate the overall accounts and annual reporting. Seems to work fine for them.

Whatever.

But it's not how it works now. It would require massive reorganisation of the CofE and there's no will to do it, particularly at the Diocese level and, as it turns out, there are only 12,500 parishes, not 35,000 as you claimed, so the Charities Commission will not be overwhelmed, especially as they could manage the registration of the new charities over several years by lowering the exemption limit gradually.

You're asking for the CofE to be completely restructured when the alternative is for the Charities Commission is to hire a few more staff.

[ProfessorDavey]

Whatever.

But it's not how it works now. It would require massive reorganisation of the CofE and there's no will to do it, particularly at the Diocese level and, as it turns out, there are only 12,500 parishes, not 35,000 as you claimed, so the Charities Commission will not be overwhelmed, especially as they could manage the registration of the new charities over several years by lowering the exemption limit gradually.

You're asking for the CofE to be completely restructured when the alternative is for the Charities Commission is to hire a few more staff.

If the CofE and charity commission wish to register the churches in this manner, then they can of course - so long as it actually happens. But I don't think it is either necessary (they could do it by diocese) not desirable - I'm not sure the CofE would really want all that effort of reporting in two different directions, as PCCs are already required to provide the financial information to the diocese for overall collation. It would seem to me that the CofE might prefer the efficiency of a single reporting of the PCCs to the diocese, which then reports on to the commission in a single block.

As I say it seems to work for the RCC and for many other charities which have a single central charitable registration but many smaller financially independent groups below that larger structure. RNLI is another good example - the central body doesn't run an individual lifeboat station, yet there is a single charity as far as I'm aware.

[ProfessorDavey]

Furthermore, there are only 12,500 CofE parishes, not 35,000. The other 22,500 charities must be related to other things than actual parishes. Registering all of the 12,500 parishes in one go might be an issue, but it could be resolved by lowering the exemption limit gradually over a few years.

The numbers are really confusing, as I've mentioned before - it seems strange that there is a claim of 35,000 excepted CofE charities requiring registration yet only 16,000 CofE churches. I'm not sure what the others can be as I though the exception was for churches specifically rather than for related charities.

But this is part of the issue - there is no list of excepted charities (for the obvious reason that they aren't registered) so we don't really know who they are, how many their are, who their trustees are, how much income they have, how they spend their income etc etc. And this in makes any kind of regulation very difficulty in practice, even if the law theoretically claims excepted charities are still regulated by the charity commission - frankly I can't see how they can be in practice as the commission doesn't even know how many of these charities exist.

[ProfessorDavey]

You're asking for the CofE to be completely restructured when the alternative is for the Charities Commission is to hire a few more staff.

I think my concern is that the CofE uses the argument of the number of registrations to secure further extensions. That is a choice for the CofE, not a requirement and should not be used to prevent the registration of church charities.

I'm also not convinced that there would be any complete restructuring required, as you suggest. This from the CofE's own resources:

The diocese is then the principal pastoral and in turn financial and administrative resource of the Church of England ...

If the diocese is already the principal financial and administrative unit for the CofE, then surely it wouldn't require any major restructuring for charitable registration and reporting to be completed at this level, following receipt of financial information from individual parishes, as already happens.

[jeremyp]

If the CofE and charity commission wish to register the churches in this manner, then they can of course - so long as it actually happens. But I don't think it is either necessary (they could do it by diocese) not desirable - I'm not sure the CofE would really want all that effort of reporting in two different directions, as PCCs are already required to provide the financial information to the diocese for overall collation. It would seem to me that the CofE might prefer the efficiency of a single reporting of the PCCs to the diocese, which then reports on to the commission in a single block.

Why? It would add work for the dioceses and the central church. As things stand, all of the financial work is devolved onto the parishes where it is performed largely by volunteers. If the central church did it, they'd have to pay people.

As I say it seems to work for the RCC and for many other charities which have a single central charitable registration but many smaller financially independent groups below that larger structure. RNLI is another good example - the central body doesn't run an individual lifeboat station, yet there is a single charity as far as I'm aware.

But these are all charities that have always been organised that way. The CofE is not and that's really the end of it.

[ProfessorDavey]

But these are all charities that have always been organised that way. The CofE is not and that's really the end of it.

But if the excepted charities have to register and report something will have to change - the status quo isn't possible. So they haven't always been organised that way, because they've never had to register and report at parish level unless incomes are in excess or £100k. So something will have to change.

[ProfessorDavey]

Why? It would add work for the dioceses and the central church. As things stand, all of the financial work is devolved onto the parishes where it is performed largely by volunteers. If the central church did it, they'd have to pay people.

But as it stands already the PCCs are required to report upwards to the diocese, which are then collated and reported onward - currently this is to Church House, so central CofE. The only difference would be that the financial reporting of the PCCs, collated by the diocese would be submitted to the commission as well as Church House.

https://www.stalbans.anglican.org/finance/annual-returns-finance/

Note You can use this page to upload your Parish Finance Return and your Accounts for 2020.  You are required to return two things to us.

Would you please return your Parish Finance Return to us by Friday 11th June 2021.  This gives us time to collate all the data and send on to our colleagues at Church House to meet their deadline.

Sure there would be a little more work at diocese level, but arguably far less than every PCC reporting separately to the commission. And also I don't understand why work at diocese level would need to be done by paid people rather than volunteers - it can still be done by volunteers at that level.

There would be an additional benefit of oversight - while small PCCs aren't registered and reporting to the commission it is hard to see how any regulatory action can easily be taken. Once they are registered there is much greater likelihood of regulatory oversight, which if there are problems will reflect onto the central CofE organisation, so they may prefer to have greater oversight.

[jeremyp]

But if the excepted charities have to register and report something will have to change - the status quo isn't possible.

Yes it is. The only difference is that all the parishes that are not registered charities will become registered charities.

So they haven't always been organised that way, because they've never had to register and report at parish level unless incomes are in excess or £100k. So something will have to change.

Organised in what way? In what way do you need to be organised to become a registered charity? As I said above, probably the only onerous task would be to get the accounts audited.

[ProfessorDavey]

Yes it is. The only difference is that all the parishes that are not registered charities will become registered charities.

But that is, of course, a significant difference as currently the parishes don't report to the charity commission annually, but they do report to the diocese annually, who collate the information for onward consideration. So actually the nearest to what happens now at parish level would be to retain reporting to the diocese by the parishes with the current collated information from at diocese level reported both to Church House and the charity commission.

Realistically the CofE could organise itself in either manner, but I'm really not sure I would want 16,000 (or 35,000) separate parts of my organisation separately reporting to and separately being regulated by the charity commission. That seems to me to be a recipe for inefficacy and poor governance.

[jeremyp]

But that is, of course, a significant difference as currently the parishes don't report to the charity commission annually

Not as significant as a complete structural reform of the Church of England, which is what you are advocating.

Realistically the CofE could organise itself in either manner, but I'm really not sure I would want 16,000 (or 35,000) separate parts of my organisation separately reporting to and separately being regulated by the charity commission. That seems to me to be a recipe for inefficacy and poor governance.

But right now the inefficiency and poor governance is not the responsibility of the Church of England, it's the responsibility of each individual parish.  Why would the central part of the Church of England want to take that on?

[ProfessorDavey]

Not as significant as a complete structural reform of the Church of England, which is what you are advocating.

I don't see why it would be a major structural reform, let alone a complete structural reform, given that the current structure of the CofE involves parishes that are overseen and responsible to the diocese. If parishes were somehow completely independent then why do they have to report to the diocese and why does the diocese have a level of governance and procedural control over the parishes. Realistically the parishes are just a local branch of a larger organisation.

But right now the inefficiency and poor governance is not the responsibility of the Church of England, it's the responsibility of each individual parish.

Not really, as the parishes report to and are responsible to the diocese. 

Why would the central part of the Church of England want to take that on?

Firstly because it already does, given that CofE accounts are collated from diocese and parish. But at the moment any dirty washing is hidden - so if a parish is a basket case the only people who really know are the higher level organisational structures of the CofE.

If on the other hand tens of thousands of parishes are reporting directly to the commission and a proportion of those (even a small proportion) are non compliant under the regulation it will be the CofE who gets it in the neck. The media won't separate out the parishes from the overall CofE, because most people don't know, nor care how the CofE operates itself. The 'news' headline would be:

'CofE fails to meet charity requirements' - with the news item reporting that 100s of CofE churches are failing to meet the commission regulatory requirements (and that might be just 1% of those charities)

So it will rebound on the CofE, so surely the CofE will want oversight, and the way to get that is for parishes to report upward in the CofE and the more centralised structure of the CofE to ensure that everything is OK before submitting to the commission.