Saturday, 18 June 2016

FC6 and FC4 forms of FCRA



FC6 and FC4 forms of FCRA

The announcement of amendments to the FCRR was made on December 15, 2015 and can be seen here. Our suggestions on those amendments, made on 29th June 2015 are available here, nearly all of which were ignored. Understandable.

In mid-January 2016, the site hosting the returns came back online. FCRA-NGOs who filed yearly returns, in late 2015 or early 2016 needed to so, in the new format. The earlier form was called FC-6, while the new one is called FC-4.

This Post attempts to identify key differences between the contents of these two forms and interprets some vital line items therein.

We shall do so through an example. Let us consider the FCRA-NGO, New India Evangelistic Association (NIEA), Zion Mannanthala, Thiruvananthapuram 695015 (KL/052910063).

A few hand holding steps to access the return:
  1. Choose 2013-14 for the Block Year and Kerala for the State. Click Submit.
  2. A long Table with six columns appears. Search for 52910063 in this page. This is the entry corresponding to NIEA
  3. Column 5 corresponding to this entry shows an amount of Rs. 107497592.94 (~ Rs. 10.7 crore) to have been received by NIEA in 2014-15.
  4. Click on “View” (column 6) next to this amount. Wait.
  5. The FC6 return of NIEA pops up. It is a HTML file.
  6. If you do the same procedure as above for NIEA, but for the year 2014-15, you will get its FC6 return for 2014-15. This is a PDF file. Column-5 in this case is Rs. 130606131.67 (~Rs. 13 crore).

We shall study NIEA's FC6 for 2013-14 and its FC4 for 2014-15.

FC6 (2013-14)

Item
Amount (Rs.)
Amount mentioned against NIEA in Main Table for Kerala State
107497592.94
Total Interest amount (mentioned as OTHER, S. No. 17 in Institutional Donors)
1571290
Total Donations from Individuals abroad
241993
Total Donations from Institutional Donors abroad
107255599 (109068882-241993-1571290)
Total Donations from Donors within India, without Interest amount (see for example S. 141, Seva Bharat)
25459647
Total Donations to NIEA directly from abroad
82037945.14 (107255599+241993-25459647.86)

Thus, the amount mentioned against NIEA in the Main Table for Kerala State (of 107497592.94) is the sum of Total Donations from Institutional Donors (including intra-India transfers) and from Individuals. The important thing to note is that the total amount include intra-India transfers.

The final directly-from-abroad amount of Rs. 82037945.14 can also be obtained in a "trivial" manner by taking the total amount mentioned at the end of the FC6 (total of country-wise remittances) and subtracting the "From India" amount mentioned in the same section of FC6).

Note that the amount mentioned against NIEA in the Main Table for Kerala (in the case of NIEA, the amount is Rs. 107497592) does not include the Interest amount (of Rs. 1571290).

Bulk analyses of intra-India fund transfers and of amounts stashed away in Bank Deposits by FCRA-NGOs were carried out in this Post. Read it to get an idea of the magnitudes involved.

FC4 (2014-15)

Item
Amount (Rs.)
Amount mentioned against NIEA in Main Table for Kerala State
130606131.67
Total Interest amount
1180657
Total Donations from Donors within India
10308979
Amount brought forward
24734769.82
Total Donations to NIEA directly from abroad
94381725.85

Thus, the amount in the last column in Table here is the amount mentioned in the Main Table minus the other three amounts (Interest, intra-India and brought forward). Thus, the total donations to a FCRA-NGO directly from abroad was a derived quantity in the FC6, while it is readily available in the FC4.

Summary:
  1. Amounts mentioned in the Main Table for a State include intra-India transfers. This is true both in the old FC6 scheme as well as in the new FC4 one.
  2. Amounts mentioned in the Main Table in the old Scheme did not include money kept in Fixed Deposits. However, in the new scheme, it includes money kept in Fixed Deposits. The latter is non-trivial.
  3. While nearly all (hopefully, but not sure) returns for 2013-14 are in FC6 format, those for the year 2014-15 are highly mixed. Many are in FC6 format, but a non-negligible fraction is also in FC4 format. Thus, the amounts mentioned in the Main Table for 2014-15 can mean different things, depending on the specific format that a FCRA-NGO has used. It is a mine field, mildly put.

P.S.: Although NIEA's FCRA registration is in Thiruvananthapuram, a large part of its field work is done in Purnea, Bihar. Tilling, sowing and harvesting comprise this work in the field.

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