DCH 126 The Fellowship of Independent
Evangelical Churches Ltd
CHARITIES BILL
Submission from:
The Fellowship of Independent
Evangelical Churches Limited
Association of Grace Baptist
Churches Limited
Grace Baptist Trust Corporation
An Evangelical Fellowship
of Congregational Churches
1 The four bodies submitting
this memorandum represent nearly 1000 independent churches throughout
the United Kingdom. We welcome the publication of the Bill and
are pleased to see that many of the concerns we have raised with
the Home Office and Charity Commission in the consultation process
have been recognised In general we are pleased with the proposals
contained within the Bill but there are two areas of concern which
remain.
2 In preparing the memorandum,
however, we have addressed the two points we wish to make from
the viewpoint of not just those small churches within our own
groups but the very many more totally independent churches and
chapels to be found throughout the British Isles who have no connection
with any denomination or other church grouping. They are in the
main, probably, unaware of the publication of the Bill and also
of such a size that they might feel any comments they might wish
to make on their own would receive little attention.
3 We cannot quantify the
number of such small village churches affected but no one who
travels throughout the country can have failed to notice the very
many small churches and those who live in the country will recognise
that many of these perform a very valuable service by being available
to the village community groups for meetings, community events
and the like. These churches tend to be run by a small group of
aged persons whose life revolves around the church and its position
within the village.
4 Registration Limit.
The proposals for the registration of all charities sets a value
level of £5000 total income in a year below which a charity
need not register (Clause 7 Section 3A). This is a welcome increase
over the previous level of £1000 but we still believe the
limit to be too low. The review carried out by the Strategy Unit
"Private Action, Public Benefit" recommended that the
limit be increased to £10~O00. Whilst many of the very small
churches will have an income of below £5000 there are other
who will exceed this figure and yet, when faced with the need
to register (if the present proposals are passed into the statute)
will cause those running the church to conclude that they can
no longer accept the onerous responsibilities of trusteeship and
registration and force the church to close. We would urge the
Committee to consider increasing the proposed limit so as to avoid
such an adverse reaction to a Bill designed to bring a degree
of regulation to charities yet not to force closure on those very
valuable but small charities such as those outlined.
5 Expenditure
of Capital.
Clause 33 introduces new powers and limits for the expenditure
of capital. We welcome this but regrettably the drafting does
not appear to us to deal with what ha8 become an Increasingly
unrealistic limitation on charities. We refer to the situation
which applies to Permanent Endowment (PE). Current rules applied
by the Charity Commission only permit PE to be expended where
it is on new land and buildings and not merely new buildings.
For many churches the result of this restriction is that money
is held which cannot be spent even though the church faces, for
instance, the need to build new disabled toilet facilities to
meet Disability Discrimination Act obligations, because the expenditure
is on new buildings on existing land. This cannot be a rational
approach to the problem and we believe the drafting of the 8i11
should permit PE to be expended on new land or buildings. It may
be that the ability to commit such expenditure should be made
subject to the approval of the Charity Commission to avoid frivolous
projects proceeding and this would be acceptable.
6 We would wish to express
our thanks to the Committee for the ability to make this submission
and trust that it will be received in the positive spirit in which
it is
made.
|
