Since 2020, more than 80 of the 1,000 largest Christian ministries in the US have asked the Internal Revenue Service to classify each of them as an “association of churches.” That means the ministries do not file a Form 990, a document that publicizes information about revenue, expenses, and executive compensation.
More than 100 of the largest ministries, including Focus on the Family, Compassion International, Convoy of Hope, and the Billy Graham Evangelistic Association, now have the classification. The failure to file a Form 990 is a “red flag” according to Calvin Edwards, founder of the philanthropic consulting firm Calvin Edwards & Company.
Edwards said, “The Form 990 has information that you can’t find in the audit, including the salaries of key employees, names of board members and large contractors, and the amount of money the organization spends on its core mission. Also highlighted are the amounts it spends on administrative and fundraising. This information is valuable to donors wanting to assess the effectiveness of a ministry.”
The ministries often say their primary motivation is protecting donors. The issue of donor disclosure went national after Brendan Eich, cofounder of the web browser Mozilla, came under attack. The reason: In 2008 he contributed $1,000 to an organization supporting California’s Proposition 8 ballot proposal, which called for a ban of same-sex marriage. The donation went mostly unnoticed until Eich became chairman of Mozilla in 2014. Public outcry ensued, and Eich ultimately resigned under pressure.
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That donation was political, not philanthropic, but it did highlight how ideologues could weaponize donor lists. In 2015, Kamala Harris, then California’s attorney general, attempted to compel nonprofits registered in the state to disclose the names of donors, but a California judge quickly halted Harris’s enforcement efforts, and the US Supreme Court in 2021 effectively barred the public disclosure of Schedule B, the part of the Form 990 that lists donors.
That means donors and ministries have stronger privacy protections than ever. Harris’s gambit eventually motivated states to start passing donor privacy laws. Today, at least 19 states now have such laws.
According to Chicago attorney David Bea, who advises Christian nonprofits (including CT), the California effort ended up strengthening, not weakening, donor privacy rights. The need for ministries to reclassify as associations of churches did not increase; it diminished.
But it also generated fear, or at least concern, among Christian ministries. Paul Batura, a spokesman for Focus on the Family, alluded to “several occasions on which non-profit organizations—on both the right and the left—were targeted for information, including the names and personal details of their donors.”
Attorney Bea said, “I don’t think all the ministries seeking reclassification are playing ‘hide the ball.’” For example, Wycliffe Associates, a large Bible-translation organization based in Orlando, Florida, filed its last Form 990 in 2008. Its former president, Bruce Smith, told CT concern for the security of its personnel working in closed countries was one of the reasons for this decision.
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But journalist (and CT contributor) Mindy Belz, who has reported from conflict zones and closed countries, said security concerns overseas do not justify a lack of transparency here in the US. “Shining a light in dark places” often enhances security, she added: “It tends to bring about pressure that is helpful rather than harmful.”
If a US ministry does work overseas, it must disclose the amount of money it spends on that work in its Form 990, but that disclosure is by region, not by individual country. Samaritan’s Purse and World Vision work in closed countries all around the world, but both organizations nonetheless file Form 990s and are transparent with US donors.
World Help’s director of international partnerships, Kraig Cole, said his organization tries to find a “balance between security and transparency.” When reporting to donors and supporters about projects in persecution-prone countries, World Help may blur faces in photos and use different names. World Help does file a Form 990, and its leadership believes none of the information in that document compromises the safety of its staff overseas.
So if filing a Form 990 compromises neither donor privacy nor the safety of ministry work, why are more and more ministries electing this reclassification? Assessing motives is always a tricky business, but some of the ministries seem to make the reclassification to avoid scrutiny. Controversial and sometimes outright fraudulent organizations have been claiming the church exemption for years. It’s a common practice of televangelists and prosperity gospel preachers.
From 2007 to 2011, Sen. Charles Grassley investigated six televangelists—Benny Hinn, Eddie Long, Joyce Meyer, Kenneth Copeland, Creflo Dollar, and Paula White-Cain—whose organizations lacked transparency. The organizations they led spent donor money on mansions, lavish lifestyles, and private jets.
When a ministry reclassifies as an association of churches, it is often an early indication of trouble to come. For example, Ravi Zacharias International Ministries (RZIM) stopped filing a Form 990 in 2015. By 2017, rumors of impropriety began to surface, but because the ministry did not file a Form 990, the public could not see that RZIM now had Ravi Zacharias’s family members in senior leadership positions, as well as in board roles. Accountability and transparency were virtually nonexistent. By 2022, RZIM—once one of the largest and most respected ministries in the country—was out of business.
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Biola University dean Ed Stetzer said ministry leaders should consider not just legal questions but biblical principles. He is skeptical of organizations that claim to be churches or associations of churches when they do not possess the essential qualities of a church.
Stetzer said, “The biblical definition of church has been an important discussion among missiologists and theologians for a long time. The Reformers often talked about the right administration of the sacraments, faithful preaching, and church discipline as indispensable marks of a church—if you don’t have those elements, you are not a church.”
He concluded, “That’s why something like a college Bible study is not a church, but 20 people meeting in a home in China can be—the marks are present in one but not the other.”
That’s why Bea said some of his clients have considered reclassification to a church or association of churches but ultimately “made the decision they didn’t think it was honest.”
Warren Cole Smith is the president of MinistryWatch.
