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Petition for Examination and Resolution of the interrelated matters of repetitive, surreptitious theft, and the sins and occasions of sin generated and countenanced by an intentionally vulnerable revenue handling process
The phenomenon of covert theft or embezzlement from the community purse can be traced back to the Twelve Apostles, and can be reasonably and logically assumed to have been a recurring phenomenon from Jesus’ time to the present day. As JOHN [12:6] chronicled, “He carried the money bag and would help himself from it.”
This petition proposes to establish that, at least throughout the United States, Sunday collection funds, the Church’s primary source of revenue, remain highly vulnerable to surreptitious theft and are thereby a leading cause of temptation to sin and actual sin within the Church. It is further postulated that the extreme vulnerability of those funds is directly attributable to the hierarchy’s knowing and willful refusal to consider readily-available, low-cost security measures that would all but eliminate not only the incidence of such thefts but also the temptation that leads to the sin of theft. The petitioner holds that the remedy requires uniform, Church-wide security measures.
The petitioner believes that his hypothesis and recommendations are supported by Holy Scripture, Canon Law and certain professional standards relating to the obligation of managers to protect income and assets. Each of those references is identified and summarized as follows:
Holy Scripture LUKE 17:1 [Matthew 18:7] - “Things that make people fall into sin are bound to happen, but how terrible for the one who makes them happen.” LUKE 12:2 [MATTHEW 10:26] - “Whatever is covered up will be uncovered, and every secret will be made known.” Code of Canon Law Book V, Title I, Canon 1265 §2: The Episcopal Conference can draw up rules regarding collections, which must be observed by all, ..... Book V, Title II, Canon 1284, §1 and § 2: All administrators are to perform their duties with the diligence of a good householder. Therefore they must: 1° be vigilant that no goods placed in their care in any way perish or suffer damage;
Statement on Auditing Standards, Codification of Auditing Standards and Procedures, issued by the American Institute of Certified Public Accountants in 1973. Pertinent sections as follows: Section 110.02: Management has the responsibility for adopting sound accounting policies, for maintaining an adequate and effective system of accounts, for safeguarding assets, and for devising a system of internal control that will, among other things, help assure the production of proper financial statements. Section 320.42: The objective of safeguarding assets requires that access be limited to authorized personnel. The number and caliber of personnel to whom access is authorized should be influenced by the nature of the assets and the related susceptibility to loss through errors and irregularities. Limitation of direct access to assets requires appropriate physical segregation and protective equipment or devices. Section 320.44: ..... agreement of a cash count with the recorded balance does not provide evidence that all cash received has been properly recorded. This illustrates an unavoidable distinction between fiduciary and recorded accountability: the former arises immediately upon acquisition of an asset; the latter arises only when the initial record of the transaction is prepared. Section 320.67: Controls and weaknesses affecting different classes of transactions are not offsetting in their effect. For example, weaknesses in cash receipts procedures are not mitigated by controls in cash disbursements procedures;” Section 320.68: The auditor’s evaluation of accounting control with reference to each significant class of transactions and related assets should be a conclusion as to whether the prescribed procedures and compliance therewith are satisfactory ..... The procedures and compliance should be considered satisfactory if the auditor’s review and tests disclose no condition he believes to be a material weakness ..... [i.e.] ..... a condition in which the auditor believes the prescribed procedures or the degree of compliance with them does not provide reasonable assurance that errors or irregularities in amounts that would be material in financial statements being audited would be prevented or detected within a timely period by employees in the normal course of performing their assigned functions.
Diocesan Internal Controls: A Framework (issued by Committee on Budget & Finance, National Conference of Catholic Bishops/United States Catholic Conference in 1995) Handling of Collections [The named document’s only reference to Sunday collection procedures] In this scenario, one person is responsible for counting the Sunday collection, making out the deposit ticket, taking the deposit to the bank, and recording amounts to parishioner records. This case is easy to detect and can be prevented by requiring a number of safeguards, including involvement of more than one individual in handling collections, dual counts and signatures evidencing concurrence of counts, segregation of the count procedures from deposit preparation, and recording of cash receipts. Furthermore, someone who is not part of the cash receipt function should double-check the receipted bank deposit ticket with an initial control log of cash receipts. Additional controls may include an independent review of bank statements and preparation of bank reconciliations, and a recheck of envelope receipts to parishioner records. Procedure to Assist Pastors in the Internal Control of Finances (issued by the Archdiocese of Boston in 1992) A copy of this document is included in the supporting papers.
Present Conditions Insofar as present-day conditions are concerned, this petition includes current examples of major intra-organizational embezzlements which establish that the referenced phenomenon has not only carried forward but has exacted a heavy moral toll in addition to its debilitating economic effects. And when one considers that Judas constituted a significant percentage of the Church’s then total membership, the weekly availability of large sums of uncounted, unsecured currency to literally thousands of individuals in the United States alone is disconcerting, to say the least.
The Issue Two basic questions lie at the root of this matter. First, to what extent is the hierarchy morally obliged to provide an adequate level of protection for cash offerings made by Christ’s Faithful and, second, to what extent is the hierarchy morally obliged to eliminate proven occasions of sin which exist within the realm of their authority and responsibility?
Insofar as the first question is concerned, there are at least two good reasons to conclude that the hierarchy is obliged to provide an adequate level of protection. The first reason is rather obvious: Christ’s Faithful give in the belief that their offerings will be used to further the work of His Church. Consequently, they have a right to expect that what they place in the collection is, in fact, properly deposited in the bank. But under the timeworn procedures now used in virtually every parish, no one can confirm that significant losses are not occurring each and every week of the year. In essence, this state of uncertainty constitutes a failure to ensure that goods placed in the Church’s care do not in any way perish or suffer damage. And the fact that, at the Conference level, this failure is both knowing and willful would appear to compound its seriousness.
The 2nd reason for providing an adequate level of protection is seldom considered but also concerns individual rights: the right of employees and volunteers not involved in the collection to be free of suspicion in the event of an unexplained loss. When security over a church’s Sunday collection is absent or weak and a loss occurs, every person having access to the areas where those funds are stored and/or processed must be deemed suspect. This viewpoint is axiomatic of sound criminal investigative and law enforcement practices.
The second question, regarding the extent to which the hierarchy is morally obliged to eliminate proven occasions of sin which exist within the realm of their authority and responsibility, is a theological matter and, as such, is outside the realm of the petitioner’s expertise. With a view toward assisting the Holy See in resolving that question as it relates to the subject of this petition, however, transcripts of newspaper articles relating to several embezzlement cases are presented as additional exhibits. In most instances, the reviewer will note that the sin of theft either led to or abetted other sins separate and apart from the theft. The petitioner maintains that, in many if not most instances, the thief’s concomitant sins would not have been committed if he or she had been denied the opportunity to commit the sin of theft.
Insofar as the hierarchy’s ability to eliminate or at least drastically reduce the opportunity for and incidence of theft from the Sunday collection, it remains for the petitioner to explain how that goal can be achieved with minimal expense and effort. This is not to imply that financial factors should in any way control a moral imperative, but rather to demonstrate that the costs are truly minimal, especially when contrasted with the great moral good they will generate. In that regard, however, it is important to note that decades of neglect have created certain entrenched attitudes at the parish level; in the petitioner’s opinion, those attitudes can only be overcome by forthright, authoritative directives which leave no doubt as to who is in charge and what must be done.
Before the level of security over any Sunday collection system can be considered adequate, the following general criteria must be met. First, the collection for each Mass or service must be positively secured, immediately after it is taken up. The method used must be such that each person in the chain of custody (from church vestibule to counting room and all points between) will know, through simple visual inspection, whether anyone had or could have had access to the funds. Second, detailed, written operating procedures must be developed for the collection, interim storage and counting operations. The counting procedures must provide for the presence of at least three counters and establish unbroken observation and control over the funds (especially the currency) by at least two (2) persons, from the moment the storage containers are opened until all funds have been counted independently by two (2) persons, verified, recorded on a witnessed bank deposit slip, and locked/sealed in a bank deposit bag. And third, each week's count must be documented via standardized forms designed so that, when completed, they clearly reflect whether or not the required counting and verification procedures were followed.
The petitioner’s personal experience has shown that the average parish can implement secure collection procedures for not more than three hundred dollars U.S. Further, that figure could be significantly reduced if bulk purchases were made at the diocesan level. When one considers the previously mentioned newspaper articles, it can be seen that the cost of implementing these procedures would, in some instances, be recovered by less than one week’s savings in collection funds that would otherwise have disappeared due to theft. Again, however, the petitioner is not in any way attempting to equate or establish a conditional relationship between the cost of the program and the moral imperative to eliminate what is virtually a Church-wide occasion of sin.
Finally, the petitioner respectfully calls attention to the fact that detailed collection security guidelines are now and have been available at no charge whatsoever. These guidelines contain complete details on how to secure a Sunday collection, including a description of the low-cost equipment required to accomplish that objective. The guidelines have been furnished to the U. S. Conference on more than one occasion over the past ten years and may be downloaded from the Internet at http://www.gis.net/~pss. A copy of those guidelines, which now include guidelines for protecting a church’s disbursements operations, is appended to the accompanying exhibits. The petitioner will be pleased to answer, to the best of his ability, any questions that may arise in connection with the Holy See’s examination, and to provide any additional documentation that might be needed to ensure that the examination can be conducted without undue impediment.
Based upon the petitioner’s experience to date, and with all due respect for the expertise, opinions and priorities of the U. S. Conference, any decision to refer this petition to the U. S. Conference without examination, deliberation and preliminary findings by the Holy See will be tantamount to disposing of the petition as meaningless nuisance correspondence. The accompanying documents clearly establish that the U. S. Conference, for reasons best known to its leaders, has no interest in creating a truly secure Sunday collection system, and is even willing to abide the recurring sin of preventable theft to ensure that the status quo is preserved.
Respectfully submitted,
[signed] M. W. Ryan
Michael W. Ryan |
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