On January 1, 2018, CCMBC Legacy Fund Inc. (Legacy) commenced operations to provide support to CCMBC, MB churches, and MB pastors. This is the Resourcing Ministry service of CCMBC, one of the four core ministries that CCMBC has committed to provide. In addition, Legacy will also be responsible for the majority of the administration functions for the Canadian conference.
The first phase of this transition included the establishment of a new general ledger, new bank accounts, and the transition to Legacy of all CCMBC support staff in finance, information technology, infrastructure management, and administration of the mortgage ministry provided to MB churches and active MB pastors. The CCMBC Communications team remains as part of the CCMBC operations. This team supports provincial conferences and national MB boards and events. The executive director, executive assistant, and Centre for MB Studies director round out the staff team continuing under CCMBC.
The structure that is now operational is aligned with the budgets presented at the 2017 AGM and passed by the delegates.
Effective January 1, 2018, Bertha Dyck assumed the role as Chief Financial Officer of Legacy. In this role, she provides financial oversight to CCMBC operations. Churches, pastors, staff, and MB members should not see any difference in how the support services are being delivered.
The second phase of this transition will be the legal transfer of the assets and liabilities that were previously part of the Stewardship operations of CCMBC. The Legacy Board recommended that the CCMBC Executive Board approve the assignment of these assets from CCMBC to Legacy. This motion was approved by the CCMBC Executive Board in December 2017. Our staff is now working with our auditors KPMG and with legal counsel Filmore Riley to finalize the valuation and legal documentation to finalize these transfers.
In early February 2018, we were advised by the Ontario Securities Commission and The Manitoba Securities Commission that our application for exemption from the requirement to file a prospectus and register as a dealer of securities was denied. Our application was based on CCMBC and Legacy being not-for-profit, charitable entities that were not in the business of trading or advising in securities. The commissions did not accept our interpretation of the exemptions, citing that the exemption from the requirement to file a prospectus was not intended to be used at the magnitude of our programs, and citing also that in the commissions’ view, CCMBC and/or Legacy would likely be considered to be in the business of trading in securities.
Although this was disappointing, the commissions provided us with alternatives that we could evaluate and determine the next steps forward. All the alternatives would lead to full compliance with all securities commissions in Canada.
In addition, we have been advised that we should curtail the acceptance of deposits for both the registered and non-registered deposits until we have been brought into full compliance with applicable securities laws. Requests for withdrawals will continue to be acted upon.
The Legacy Board recommended that we now proceed with an evaluation of the registration alternatives available to us. This has been approved by the CCMBC Executive Board. We are now working with our financial, legal, and investment consultants to re-evaluate the alternatives and make a decision as to the issuer model and the mortgage and investment models and to determine whether we will make further applications with the securities commissions. It will be important for Legacy to clearly understand what the costs and benefits are for each of these alternatives.
We are committed to the principle that Legacy be fully compliant with all applicable securities commissions and other applicable laws associated with its ministry operations. We are also committed to supporting the Resourcing Ministry service of CCMBC.