On the preceding page, you will note that my correspondence with USCCB President Francis Cardinal George resulted in a referral to the Diocesan Fiscal Management Conference (DFMC) based upon their involvement in creating (in Cardinal George’s words) “guidelines for accounting practices and financial services in the dioceses in the United States.”

I have taken a few runs at the DFMC over the years, dating back as far as 1990, but failed to receive even the courtesy of an acknowledgement. With a view toward going the proverbial last mile, however, I wrote the DFMC official to whom Cardinal George had directed me in February 2008. True to DFMC form, however, he never responded, and a follow-up letter to the then DFMC president in August 2008 also failed to yield even the courtesy of an acknowledgement.

With that as a background, you’re now in a better position to appreciate the chain of communication that begins with the text of an email sent to the DFMC Board of Directors (14 individuals) on 2-22-09. As of the date of this posting (3-10-09), not one of the 14 has acknowledged receipt.

+++++++++++++++++++++++++++++++++++++++++++

----- Original Message -----

From: M. W. Ryan

To: Selected Recipients [Bcc: <dmstremel@dcdiocese.org>, <bbuckingham@dioceseofsaginaw.org>, <mike985@comcast.net>, <KMarzalik@archchicago.org>, <garnold@dioceseofcleveland.org>, <drwaynard@aol.com>, <jshewmaker@archindy.org>, <bcox@evansville-diocese.org>, <Joan.Loffredo@dioslc.org>, <watson@dioceseofvenice.org>, <wdunlop@archtoronto.org>, <rquinn@dioceseoflafayette.org>, <lzigmont@theadom.org>, <LesMaiman@dfmconf.org>

Sent: Sunday, February 22, 2009 4:19 PM

Subject: A Lenten request

Greetings;

I'm writing in follow-up to my email of November 24 which, for the record, was directed to thirteen (13) DFMC Officers and members, not one of whom acknowledged its receipt. Under normal circumstances, that would appear to be a shocking result, but my past experience with the Conference (which dates back to 1990) renders the result more or less standard operating procedure for DFMC communications.

In fairness, however, I note that my prior email did not include a specific request for acknowledgement, and that might possibly account for the result. Still, prior written correspondence to Accounting Practices Committee Chairman William Weldon and, subsequently, then President Robert Cox also went unacknowledged in spite of my clearly expressed desire to hear back from each of those gentlemen.

What I find especially noteworthy about Mr. Weldon's failure to reply is the fact that I was referred to him by USCCB President Cardinal George, a fact I mentioned in my letter to Mr. Weldon. Were I Mr. Weldon, nothing short of a permission slip from Cardinal George (or Bishop Trautman) would have kept me from replying. Even then, however, my Christian upbringing and professional career would not have allowed me to ignore such correspondence. Every written inquiry deserves a written response; it's common courtesy.

In any event, I find the DFMC's unwillingness to discuss (let alone address) the extreme vulnerability of the Church's principal source of revenue both stunning and appalling. Because of that, I will share with you what I view as the most likely excuses for the failure of the DFMC to act upon this nationwide deficiency which so clearly begs to be addressed.

Excuse #1: The DFMC has been informed that the USCCB is not empowered to direct how Sunday collections will be handled in the various dioceses and archdioceses, that authority being the exclusive purview of the local bishops. Consequently, the DFMC's development of a standardized procedure would be pointless.

Response: The USCCB's claim of inability to act is a red herring. Canon 455 clearly provides the means by which conferences may request authority to issue "general decrees" for conference-wide application. While they will never admit it and, consequently, for reasons best known to its past and present leaders, the USCCB does not wish to issue guidelines they know would bring a virtual end to the phenomenon of Sunday collection embezzlement.

Excuse #2: Differences between dioceses and parishes preclude one set of guidelines being suitable for all. For this reason, the matter is best addressed by each diocese developing its own unique standards.

Response: While the Sunday collection may be unique to the Roman Catholic Church, it is essentially the same from parish to parish, varying only by dollar amount and number of individuals involved in its collection, transport, storage, counting and banking, the very operations for which minimum standards can and must be established to ensure that every dollar placed in the collection baskets on Saturday evening or Sunday morning does, if fact, reach the bank. Anyone who claims there is more than one practical way to effectively secure the Sunday collection either doesn't know what they're talking about or has ulterior motives for taking that position.

Excuse #3: The DFMC is precluded from acting in the matter, either because of limitations built into its charter or a (most likely unwritten) USCCB directive prohibiting DFMC involvement.

Response: In paragraph 21 of your Standards for Ethical Behavior & Professional Conduct, you state "We will implement policies and procedures to protect the resources of the Church from fraud, misuse and waste, and to provide accurate and reliable financial reporting." That strikes me as a pretty clear commitment to revenue protection, and what better starting point could there be than the point where the majority of the Church's monetary resources is initially received. I leave it to you to answer the question of whether the USCCB has prohibited you from acting in the matter. Frankly, I wouldn't be at all surprised.

Excuse #4: Most if not all diocesan fiscal managers oversee parish-level audit programs and would take appropriate action to secure any parish's Sunday collection a diocesan audit showed to be in jeopardy.

Response: With all due respect, you can't audit what isn't there and, by their very nature, virtually all Sunday collection embezzlements are committed before the funds have been counted and recorded. The AICPA said it best when they declared "..... 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." In the case of a Sunday collection, fiduciary accountability begins when members of the congregation place their offerings in the collection basket. In a typical parish, however, several people (clergy, employees and volunteers) have lone, unobserved access to the collection or a portion thereof prior to its tabulation and deposit.

You might well be able to articulate one or more additional excuses for the DFMC's failure to effectively protect the Church's principal source of revenue. But no matter how many excuses you come up with, they're only excuses; there neither is nor ever can be a valid reason for the DFMC's failure to act in this matter.

When I ponder the hierarchy's knowing inaction in light of the great temptation to sin highly vulnerable Sunday collections constitute, I am invariably reminded of two things. The first is Jesus' admonition to his disciples: "Things that cause sin will inevitably occur, but woe to the person through whom they occur." [Luke 17:1) The second thing that comes to my mind is nonfeasance: failure to do what ought to be done. And I ask myself how, Sunday after Sunday, bishops can stand on the altar, and DFMC officials can stand in the pews, reciting the Confiteor and not feel a twinge of conscience when uttering the words "and in what I have failed to do".

Frankly, it would tear me up to know I had allowed myself to be cowed into silence or inaction on a clear-cut matter of faith and morals. The extensive and painfully detailed coverage of the predator-priest scandal strongly suggests that a number of bishops have become immune to feelings of guilt and personal responsibility. It's time for the laity, especially those in positions of authority, to force this issue and bring to fruition what could and should have been accomplished two generations ago.

May this Lenten period be a time of deep introspection and spiritual renewal for us all,

M. W. Ryan

www.ChurchSecurity.info

+++++++++++++++++++++++++++++++++++++++++++++++++++++++++++

The day after I sent that email, the DFMC official I had written more than one year earlier, penned a reply to my 2008 letter. His reply is shown below and my response follows thereafter.

+++++++++++++++++++++++++++++++++++++++++++++++++++++++++++

Michael W. Ryan

1372 Brush Hill Road, C-301

Milton, MA 02186-2373

March 3, 2009

PERSONAL ATTENTION

Mr. William G. Weldon, Chairman

Accounting Practices Committee

Diocesan Fiscal Management Conference

Post Office Box 60210

San Angelo, TX 76906

Dear Mr. Weldon:

Thank you for your letter of February 23 concerning my letter of February 1, 2008 that was directed to you at the suggestion of USCCB President Francis Cardinal George.

If I understand your reply correctly (and reading between the lines), neither you nor the Accounting Practices Committee you chair have been tasked with the responsibility of developing comprehensive procedures for securing the Church's principal source of revenue: the Sunday collection. As I read it, your mission and that of your Committee is to "represent" the Church before regulatory bodies such as the Financial Accounting Standards Board and the American Institute of Certified Public Accountants (AICPA) of which you are a member.

Again reading between the lines, I gather your primary focus and that of your Committee is not upon accounting and financial issues relating to parish operations where the bulk of the Church's revenue (much of it in the form of loose cash) is first received, but rather upon diocesan operations where most if not all of the revenue received is in the form of secure, non-negotiable instruments. Assuming my understanding is correct (your publication Diocesan Internal Controls seems to support that), I can only shake my head in astonishment at the almost total lack of concern the Church's fiscal experts (arguably its fiscal watchdog) have for the Church’s principal source of revenue.

You mentioned representing the American Catholic Church before the AICPA, Mr. Weldon, and I wonder how you or any member of the DFMC could be comfortable doing so, knowing the Church's principal source of revenue has been afforded none of the protections called for by the AICPA's own standards as contained in their 1972 authoritative guideline entitled Statement on Auditing Standards - Codification of Auditing Standards and Procedures. Sections 320.42, .44 and .67 of those guidelines, for example, are highly relevant to a financial operation such as the Sunday collection.

While the Church could and should have applied readily available security procedures and equipment as long ago as the 1950s, the AICPA's 1972 guidelines surely constituted the basis for prompt creation of effective measures establishing a uniform level of protection for the Sunday collection nationwide. Yet here we are nearly 40 years later with the Sunday collection in virtually every diocese in the nation as vulnerable to surreptitious theft in 2009 as it was in 1909!

You and I know what's going on, Mr. Weldon; the bishops want nothing to do with a genuinely secure Sunday collection system. Since they refuse to admit it, however, we're left to speculate on our own as to their motives. One only need review (as I have) the embezzlement case histories that have been aired in the media over the course of the past 20 years to recognize one very plausible motive: a large percentage of the embezzlers (by my count, over 50%) are members of the clergy, and we both know the lengths to which a disturbing number of bishops went to protect sexual-predator priests. Couple that with the fact that an unknown but no doubt significant number of those predator priests financed their heinous predations by pilfering unprotected Sunday collection funds, and I believe we're seeing the very face of evil. Indeed, I can't imagine what could be more evil than the purported guardians of morality financing the commission of sexual crimes through their knowing and intentional nonfeasance.

At this point, you're probably saying to yourself "Why is this man telling me all this? I’m just a small cog in a big wheel; I don't call the shots!" I'll go one step further, Mr. Weldon, and allow that you might well even have been told Sunday collection security is not a matter for you, your Committee or the DFMC itself to worry about; that it is, in fact, forbidden territory. No matter what justification you may offer as the basis for the DFMC’s inaction, it neither is nor ever can be valid. I realize we’re in the midst of a great economic upheaval, making positions at your level something to be prized and protected. But some injustices and iniquities are of such great import they demand remedial action by those in a position to act in some way, even if such persons lack the power to completely remedy the situation. I have no doubt the hierarchy’s de facto conspiracy of nonfeasance meets that definition.

In my August 15, 2008 letter to then DFMC President Robert J. Cox, I acknowledged that he has no authority to dictate to the USCCB what they must do. I also noted, however, the DFMC is not without any means of persuasion, and I suggested the Board of Directors issue a white paper that could well provide the USCCB leadership with an incentive to stop dissembling and do the right thing. I now make that same suggestion to you, Mr. Weldon. The alternative, as I see it, is for you and the DFMC Board of Directors to wait for this scandalous situation to be aired in the mainstream media. When that day comes, the USCCB’s “We are not empowered” mantra will be seen for what it is: a shameful and thoroughly discredited red herring unworthy of moral men, let alone prominent religious leaders. Then, the primary questions for the DFMC will revolve around what efforts, if any, it made to show the bishops the error of their position. How would you and Mr. Stremel answer that question today?

Most sincerely,

[signed] M. W. Ryan

Michael W. Ryan

cc: Daniel M. Stremel, President, Diocesan Fiscal Management Conference

Francis Cardinal George, President, U. S. Conference of Catholic Bishops

++++++++++++++++++++++++++

EPILOGUE

Our hierarchy is in a difficult position. For generations, they have ignored and/or evaded the issue of Sunday collection embezzlement and, even today, apparently believe their interests are best served by continuing to evade it. As a result, the best interests of Christ’s Church and the Faithful (including those who fall into sin due, in no small part, to the collection’s extreme vulnerability) have been relegated to the proverbial back burner and will remain there unless and until our hierarchy is forced to address the issue in a proactive manner.

As you have noted from the documents and summaries posted at this site, the initiation of corrective measures will apparently require far more pressure than the author has been able to exert to date. You are therefore earnestly invited to join this crusade. Whether you act at the parish, diocesan or national level, this (we hope you agree) worthy cause can use all the support it can muster.

If you would like to know more about the author's system for securing a Sunday collection - or perhaps even download a copy of his guidelines (which are free for the taking and include guidelines for securing a church’s disbursements operations) - go to the Why & How portion of this website.

ChurchSecurity.info

E-mail: author@ChurchSecurity.info