According to the letter, on July 20, GFA staff reported the failure to properly disclose cash carried into India during the years 2013, 2014, and 2015 to the Department of Homeland Security.
"On July 27 and in subsequent meetings, GFA staff indicated that GFA has not received and does not anticipate any further follow-up from the Department of Homeland Security on this matter," the ECFA noted.
During its assessment of the accounting practices of GFA, the ECFA was also informed that GFA India made a gift to GFA of $19,778,613 in 2013 to complete GFA's new office in Texas.
"On August 27, GFA's staff confirmed that the funds relating to this donation were originally received by GFA as gifts restricted for the field and GFA transferred to field partners to fulfill donor restrictions," noted the ECFA.
The ECFA said this was a violation of their standards but noted that GFA staff had informed them that it was Yohannan who suggested the idea to the organization's partners in India.
"Reallocating gifts donated for field purposes and using them to pay for headquarters construction appears to be a violation of ECFA's Standards 7.2. GFA staff stated in a recorded GFA staff meeting that you approached the field partner and explained that GFA could borrow the funds in the U.S., at less than desirable terms, for the headquarters construction," said the ECFA in the letter to Yohannan.
"However, a gift from the field partner, in lieu of GFA borrowing the funds, would allow GFA to complete the new headquarters and thereby save interest. Therefore, GFA would be able to send more money to the field in future years," it continued.
The ECFA charged, however, that the potential savings resulting from the GFA India gift is an inadequate basis to reallocate gifts donated for field purposes.
"Reallocating gifts donated for field purposes contradicts GFA's claim that 100 percent of funds are sent to the field. In fact, a significant amount of donations restricted for the field made a circuitous trip back to GFA and were used for the headquarters construction, as though they had never gone to the field. This appears to be a violation of Standard 7.1," the ECFA charged.
Throughout the entire assessment process, the GFA claimed to have had no knowledge of what was happening whenever financial irregularities were pointed out or would state that the organization had no control over what their foreign partners did, but the ECFA has challenged this defense.
"At several points in our review, GFA staff has disclaimed any control over field partners, including Believer's Church in India, which oversees all other field partners. Whether GFA has control or does not have control over its field partners has a significant relationship to a number of issues, including disclosures of related-party transactions in the audited financial statements, oversight of the use of resources of field partners, board approval of related-party transactions, and truthfulness in communications," said the ECFA.
The accountability organization pointed out that GFA's staff stated Yohannan's responsibilities and powers as the Metropolitan Bishop of Believer's Church, as included in the Believer's Church Constitution is significant.
Among other things, Yohannan "functions as the president of the Synod, the Conference of Bishops, General Assembly, institutions, and every other official body of the Church as may be established or constituted from time to time…."
It further noted that: "it appears that GFA staff has significant influence on the operations and decisions of GFA field partners. This influence has been evidenced in the announcement of vast revisions in maintaining or spending down cash balances held by field partners, the change in tracking expenditures for consistency with how funds were solicited, and ceasing the use of local funds to partially cover donor restrictions."
"Based on this level of oversight and control as well observed during our review, ECFA staff questions whether GFA has a sound basis to disclaim any control over the activities of field partners," said the ECFA.
Matthew and Jennifer Dickson, who are listed as plaintiffs in the lawsuit, charge defendants in the case with violations of RICO and the Arkansas Deceptive Trade Practices Act, as well as fraud and unjust enrichment.
Listed as defendants along with Yohannan are: his wife, Gisela, a member of the Board of Directors of GFA; his son Daniel Punnose, also a member of the Board of Directors of GFA and a vice president; David Carroll, who serves GFA in multiple capacities, including Chief Financial Officer; and Pat Emerick. Emerick, according to the suit, is a United States citizen who resides in Ontario, Canada. He serves as the director of the Canadian affiliate of GFA.
The Christian Post is still awaiting a response from the GFA on the lawsuit.