Wednesday, 27 September 2023

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COC did what was required in the best interest of the Church

This post was submitted via Readers’ Contribution


By a ex-church member of City Harvest Church

I would like to respond to the recent article where a member of the church wrote in on his opinion, on the proposal to remove the 8 City Harvest Church (CFC) individuals from their posts.

As a citizen of this country and an ex-member of the church, I was surprised by the contents of what he shared and decided to look into the matters.

As I discovered, the purpose of the Charities Unit is to provide secretariat support to the Commissioner of Charities (COC) and is therefore in no way involved in this current matter. As quoting from the “About Us” section of the website “Charities and IPCs with charitable objectives related to religion, arts & heritage, environmental protection or improvement, animal welfare, or which do not fall neatly under the above sectors are under the office of the Commissioner of Charities.”.

At the said website, I chanced upon a PDF file that would suggest that the Commissioner had been more than considerate towards the 9 individuals. (You may find it at the front page of the website, “refer to the COC statement here.”.)

1) With Reference to The Church as a Family

As a member then, I understood, supported and endorsed the Crossover Project in its initial stage. The decision was made through an Extraordinary General Meeting, attended by mainly Executive Members of the church, of those, most would be cellgroup leaders, possibly 90% or more, which would possibly be supervisors/ department heads, if you were to translate that to a secular organization chart. While I did view the leaders as spiritual parents and we trusted them to manage all matters and decisions pertaining to the vision, mission of the Church, I had come to realize that the well-being of us, the members, are largely in the hands of the cellgroup leaders/ Executive Members, unless one is privileged to be a personal friend of the pastors. What we have given financially is thereafter placed under the care of the Church, whose Board had been elected by us, the members(as represented by the Executive Members), to be the Trustees. Then and now, I have no information as to how these Trustees were appointed/ nominated to be elected to the Board.

In reading up at Wikipedia, , I came to understand that the governing authority, the Commissioner of Charities, as appointed by the Government of Singapore, was given cause to be concerned that there may be financial mismanagement/ misconduct. This was brought up to him from member/s of the Church. While I recognize that City Harvest Church is a Church, a religious entity, I also understand that this same religious entity was registered in Singapore as a Charity, and is therefore under the care, authority and jurisdiction of the Commissioner of Charities, as appointed by the Government of Singapore. City Harvest Church is therefore liable to abide by the Laws and Statutes pertaining to charity organizations.  This fact, to my memory, was also pointed out by Pastor Kong himself during a service when investigations of these allegations first began.

With specific reference to this investigation by COC and CAD, even though both organizations had not been with the Church since Day 1 and may not understand the workings of the Church, their concerns being financial mismanagement/ misconduct on the part of the 9 individuals, I opine that the requirements of the investigation to be purely financial literacy, accounting principles, and legitimacy of actions with reference and adherence to the Laws and Statutes of the land upon which the Church exists which, in this matter, would be Singapore. In understanding that the Commissioner of Charities is likened to be the “big brother” appointed over religious entities which are registered as a charity, it is therefore necessary for the Commissioner to look into matters pertaining to the Church, however paternalistic this act of responsibility may seem.

2) Lack of empathy and compassion?

While I do not understand why members of the Church are prohibited from fund raising to help bear the costs of legal fees, the 9 individuals were able to post bail of $500,000 each.  As someone who have no experience with legal professionals, I guess that sum of money could possibly cover a substantial portion of legal fees till date. I do agree that these leaders have aged parents and young children to feed, medical and school fees to pay, bills to take care of, just as most of us do. But, even as they were called to serve as staff of the Church and they regard this calling as their life’s mission, notwithstanding the fact that is not a random job that they have chosen, it is still considered a job in the clergy by most people outside of the Church. And they have chosen an affirmative response to an offer of employment by the Church, which happened to be a registered charity organization.

While they had been suspended since 2012 – their source of income may not have been cut off, as explained by Jason Saint-John, on this news site,, from whom I quote:”The fact is: they may have had their assets frozen, but at law they are open to apply to the court for funds for basic sustenance for themselves and their families. Obviously, if (or when) they are proven guilty, they’re going to have to pay it all back if they had been derived from tainted funds.”. Just as the jobless in Singapore can seek assistance from their MPs, I would not jump to the conclusion that “no help from any government body would be extended to them at this point in time because of the impending trial”.

In my understanding that the Commissioner of Charities is investigating allegations of financial mismanagement/misconduct, I would conclude that the Commissioner of Charities is NOT being overzealous in its mission of “becoming a proactive and pre-emptive charity advisory” (one of their strategic objectives). It surprises me that the member assume that the Commissioner of Charities is denying these 8 individuals their rights to provide for their children, and fulfill their filial duties – to provide for their aged parents. The actions of the Commissioner of Charities to date had not been heavy-handed and some of these individuals are even allowed to travel overseas to speaking engagements, which they may be financially compensated for speaking at. I do not think that the Commissioner of Charities can stop these individuals from working, apart from their suspension from office.

With this in mind, while their source of income may be affected, it had not been completely cut off; while they are denied financial assistance from church members, possibly no one can confirm if they would receive financial help from government bodies; there also remains other options from which they can derive a source of income–  It would seem as exaggeration to me that Commissioner of Charities’ actions are “akin to casting judgement upon their (natural) family members too”.

3) Unfair, Unjust and Underhanded tactics? Or misunderstood/ misrepresented facts?

I quote the original article:

It was communicated to the 9 suspended individuals (Ms Ho Yeow Sun included) on 28 December 2012 that the COC would defer the next stage of any regulatory action should they collectively agree to a voluntary extension of their suspension orders until 6 months after the conclusion of the criminal trial. This proposal was (I quote from COC’s press release) “to allow the affected parties time to focus on the criminal proceedings, and also to have sufficient time to make their case during the removal process, should they decide to.”

On 14 March 2013, the premise (of the collective agreement) of the agreement to the voluntary suspension was changed.

From the PDF document response from the CoC, the author seems to be unaware, or neglected to mention:

By 7 February 2013

8 of the 9 suspended individuals agreed to a voluntary extension of their suspension orders.

From 22 February to 25 March 2013

The COC was prepared to defer the next stage of regulatory action against all the 9 suspended individuals, as a concession to the 8 consenting individuals.

Given that the premise for which consent provided by the 8 consenting individuals had changed, the COC felt that it was necessary to check with the 8 consenting individuals whether they would remain agreeable to voluntarily extend their suspension.

During this period, the COC communicated with, and sought confirmation from the 8 consenting individuals if they would remain agreeable to voluntarily extend their suspension, notwithstanding the lack of consent by one individual.

Extensions were given for the individuals to properly consider their decisions.

Only 5 out of the 8 consenting individuals eventually agreed to confirm their agreement to voluntarily extend their suspension.

Seeing the situation as put forth by the Commissioner of Charities in his statement, I understand that, he had graciously suspended the 9 individuals from office, instead of removing them, as is required during the phase of investigation.  Out of goodwill, he had offered these 9 individuals voluntary self-suspension as he is, by limitations of the Charity Act, unable to suspend anyone from office beyond a period of 12 months. (Refer to Charities Act (Chapter 37), Part 5, Section 25(10)). Notwithstanding that he received only 8 agreements instead of 9, despite having almost 6 weeks for these individuals to discuss and decide, the Commissioner of Charities was still prepared to offer deferment from the act to removal of the 9 persons. As the circumstances differed from the original proposal, “the COC felt that it was necessary to check with the 8 consenting individuals whether they would remain agreeable to voluntarily extend their suspension.”.

Over a period of about 4 weeks (from 22nd February 2013 to 25th March 2013), the COC communicated with, and sought confirmation from the 8 consenting individuals if they would remain agreeable to voluntarily extend their suspension, notwithstanding the lack of consent by one individual.  The 4 weeks included extensions (possibly of time). Quote: Extensions were given for the individuals to properly consider their decision.

Only 5 out of the 8 consenting individuals eventually agreed to confirm their agreement to voluntarily extend their suspension. In view of the limitations imposed upon the Commissioner of Charities by the Charity Act (Chapter 37), that he had offered the 9 individuals ‘voluntary suspensions’ instead of removal action upon the lapse of 12 months suspension, considering that he gave the 9 individuals a concession, to proceed with voluntary extension of suspension orders despite 1 non-agreement, taking the time and trouble over the period of 1 month to allow the 8 individuals to reconsider their decision… to only receive 5 confirmation to voluntary extension of their suspension.

I opine that the Commissioner of Charities had done above and beyond what is required of him professionally, in the best interest of the congregation, to not remove the leadership from office. Specifically mentioned was the absence of written agreement of Pastor Kong Hee and wife.

Quote from

As I stated in my earlier statement, the COC subsequently informed me, on 14 March 2013, that the premise for our agreement to the voluntary suspension had changed. The COC revised the terms of the original offer, and abandoned the requirement for unanimous consent as one individual did not consent. When I asked for clarification for this change of position, the COC informed me that the risks of the lapse of that individual’s suspension order could be managed.

Given that the premise for the COC’s offer had changed, and the fact that Sun and I had already agreed to the voluntary suspension on the COC’s original terms in February 2013, we did not see any reason to consent again to the revised offer. As I stated in my earlier statement, we informed the COC that we had already agreed to the voluntary suspension on the COC’s terms.

The requirement by Commissioner of Charities was for a “written confirmation” from the 8 agreeable individuals that they would agree to the voluntary extension of suspension as to defer from removal from office, despite a non-agreement from 1 individual.  It baffles me that he, as an Honorary Doctorate Business Administration holder, a Doctor of Theology, chose not respond in a manner as requested by the Commissioner of Charities.  His academic achievements affirms his ability to comprehend the requirements put forth by the Commissioner of Charities, and yet he chose not to respond in the manner as required by the Commissioner of Charities, appointed by the Government, with authority over charities, of which he falls under the jurisdiction thereof.  A man as brilliant as he seems to be, it would be unbelievable for me if he should be ignorant of the fact that “where a written confirmation is required, a verbal response is insufficient”. Assuming the benefit of doubt, that he truly believed that a verbal response would suffice… how much trouble would it have been for him to pen a response to the Commissioner of Charities, even if he were to personally do it, as compared to all the public clarifications that are now transpiring?

In conclusion, I feel that, within the context of the current situation, the Commissioner of Charities have done what he could, possibly above and beyond what is required of him by his Office, in the best interest of the Church, to minimize the necessity to enact the removal of the 9 individuals, which is necessitated by the lapse of the 12 months’ suspension, as required by the Charity Act(Chapter 37).

Commissioner, you have my respect.

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