Top Risk Management Issues for Churches

[Music] Let's talk about minimizing how we can minimize the liability with a minor. So yeah, let's start with a written application.

Mhm. So, um, if you have your volunteers having a written application filled out, okay? In that written application, you should be getting permission to run a background check. And you want to talk about what goes into that background check.

Yeah, well, that would be like the second uh step. You know, the first step is the written application in terms of risk management, uh, and I think the second step is an interview. Right? If you don't really know this person well, you know, why do you want to be involved in some capacity in the church involving youth or minors? And that's what we're talking about here. And then number three, which I think is the uh is the uh most important ingredient in Risk Management in this context is doing reference checks. And I don't mean reference checks from people you've never heard of before. I see churches do this all the time. They get references: "Here's a church in Missouri," and they do reference checks on this guy that wants to teach kindergarten uh that comes in off the street with sunglasses and a trench coat and who wants to work with children you never heard of. "Oh good, you're an answer to our prayer," uh, and you put them to work right away. Uh, you know, that that the best way to screen somebody like that is not even a criminal records check, which we do will recommend here shortly, but it's an Institutional reference. And by institutional reference, I don't mean an individual reference. I mean a reference from another institution where this person has worked with minors. Who better to evaluate this person's fitness for working with minors than some other organization that is using him with minors? And that's going to be another church or churches; that's going to be Scouts; that's going to be teaching; coaching. There's any number of ways people are—it's rare for somebody to say out of the blue, "Well, I want to start working with minors." Uh, usually people have a record and they've worked in other facilities. And so to get two or three of those other organizations and uh that have observed this person uh maybe other churches in your community in some in some cases and and get a reference from them. The ultimate question is: Do you know of any reason why this person would not be suitable for working with minors in our church? And if you have three or four of these entities say no, that's the gold standard. You can't beat that. Now, uh, but but what happens is churches just get references from people. You must get institutional reference. If if a person in fact has never worked with minors before, that's a red flag. But in that case, you're left with references that are individuals, but I would limit it to members of your congregation at that point, not unknown people.

Let's go ahead and talk about, you know, using members of your of your congregation. How long should they be a member of your congregation before you would think that they should be used? That's the fourth risk management principle. You know, we've talked about the application; we've talked about the interview; we've talked about the institutional references. The fourth component I think is uh what I call the six-month rule. I've called it that for 20 years, and you know people quibble over, "Well, you know, can we make it can we make it just attending the church for six months?" I have always uh adopted the rule of membership for six months. If you want to make it a year, that's fine with me, but it the person is subjected to the discipline of the church, and uh I I just—and furthermore, it takes a period of time for the person to qualify for membership, so you have more time to observe this person. And that's what you want to be able to to share. If there's a case of child molestation and you're sued for negligence in selecting this person, it just is going to help you as opposed to taking a person off the street, giving them 30 days is attending the church sporadically. That's that that's the other end of the spectrum. And so uh I have followed that rule for—now there will be certain exceptions to that. For example, if it's going to be a paid employee, let's say a children's Pastor, they're not going to be a member of the church for six months. So, but we're talking here predominantly about volunteer workers, which is the preponderance of of people that work with minors.

Let's go back to a background check. What should actually be in that background check? Well, here we're talking about uh criminal records checks largely, and I think the two principal components of—and this is really the—are we up are we up to number five now? Yeah, the the the criminal records check uh in my opinion is is twofold: You need to do a national criminal file and you need to do a uh a national sex offender public registry check to see if this person's on a on a sex offender registry, not in your state, but Nationwide, which looks at all 50 states simultaneously. And that those are the two critical components. And you know there there are a number of companies now that do these components for a relatively minor charge, under $10 per person. And so that that is something that we recommend. Some Churches think that just doing the criminal records checks are enough. The two adult rules: So never let a never let a child be alone with one adult. Always make sure one child alone with one adult. Yeah, because you know it's typical for Sunday School classes of children, for example, to have multiple children with one adult. And that's the public school model. You go to your public school down the street; you go into a third grade classroom; there's 30 kids and one teacher. That doesn't—I mean, why why some Churches think, "Well, we have to have two adults in every classroom." If that's what you want to do, if you have the manpower to do it, go for it, but it's just it's an it's an excessive principle that uh is not necessary. I think if you align your practices with the public schools, that's that's the state that's a state instrumentality, so you're demonstrating the exercise of of reasonable care. I think if you follow the state principal and the state principal is not having two adults present uh in in classrooms, although some do.

You do have a registered sex offender in the church. Okay, how should the church handle it? I think there's two ways. You may disagree with me, but I think there's two ways that the church can handle it. Let's talk about those.

Well, I think there three ways uh actually. Uh, the first way is probably what most churches do, and that's nothing. Uh, they don't know what to do. They maybe they haven't thought about it. Uh, it's just not an issue that's that's risen to the level of urgency where Church leadership feels we need to do something about. We do not recommend that. Now the other two options would be uh a policy of total exclusion: totally exclude all registered sex offenders. Uh, some Churches do that. The largest survey Jerry ever done of church practices in this country with regard to how to handle sex offenders on your premises was done by Christianity Today three years ago, and it was interesting. The in this survey, one of the questions was: What do you think the appropriate response would be to knowledge that you have a registered sex offender attending your congregation? And of those that said the appropriate response is total exclusion of that person, I was I have to admit I was a little surprised with that. It was only 3% said that we would totally exclude that person. Now I will say that in my opinion there are some situations when I think uh total exclusion is appropriate. Let me just mention two of them. One would be if the crime or the crimes for which this person was previously guilty put him on a sex offender register are particularly heinous, um, and this guy's out of prison for whatever reason. Uh, you know, the uh the Adam Walsh Child Protection Act of 2006, uh federal law that requires all states to have sex offender registries, requires the national government, the federal government, the F the Department of Justice to implement a sex offender registry that's accessible by the public. Uh, that particular statute segregates sex crimes into three categories: Tier one, Tier two, Tier three. And uh Tier one are the least offensive crimes; you're on that registry for just 15 years. Tier two are more severe crimes, sexual-oriented crimes, and you're on the registry for 25 years. Tier three are the most heinous crimes; you're on the on the registry for life. So the point is if you have somebody that's a Tier three sex offender, this person has been determined to be the most severe category of crime. So I I would say that for Tier three offenders, Jerry, you you may be able to make a case, I think perhaps easily in fact, that maybe these people ought to be scrutinized very carefully. And then so uh with respect to um total exclusion, so some crimes are so heinous that I think they should be excluded from church. The second reason I think a Church may want to adopt this policy is if some of the offender's victims still attend the church. And so the point here is this frequently happens: Maybe one or more of this person's victims continue to attend the church, and uh does the church should it not intervene here and protect the victims from being revictimized every Sunday by seeing this guy? Uh, not just the victim, but their families, their mothers and fathers, their parents, their siblings, their grandparents perhaps uh to to have this continual revictimization stop it. I in my opinion that's another reason. So that's that's the second response churches have. The first response is doing nothing. The second response is total exclusion, which as I say may be appropriate for Tier three offenses that are particularly heinous uh or if victim one or more victims continues to attend the church. Now the Third third option that a church has, in fact, according to the Christianity Today survey, this was the option selected by about 80% of churches when asked: What do you think the appropriate response would be? And that's getting to your point of the U uh limited attendance agreement: that the person is free to attend the church as long as he or she signs a limited attendance agreement that has a number of features to it. And I think and we'll talk about that in a minute, but I think that type of approach really resonates with church leaders. It's more merciful; it's less harsh; it's less condemning; and uh and I think if it's worded properly, this can put the church in a position of being viewed as having acted reasonably under the circumstances, which means that it can't be it's probably not going to be negligence.

What kind of thing should be in a limited or a conditional attendance agreement where we are going to allow 80% of churches say they do this uh that we're surveyed, we're going to allow a registered sex offender to attend, not mainstream this person as a worker with children, but just let this person attend. That's what we're focusing on today. Obviously, you don't want to use that person uh in a capacity as a teacher. In my opinion, uh, you know, I I think of James chapter 3, verse one that says: "Not many of you should become teachers, for we who teach will be judged more strictly." I think that's a Biblical mandate that when it comes to people that we set aside as teachers, there's a stricter standard that applies. And if somebody's a registered sex offender, that person just doesn't meet that standard. I think most right-thinking reasonable people would would come to that conclusion. So so we're not talking about that issue today; we're talking about the related issue: Well, what if the person doesn't want to work with children, just wants to attend the church? What what do you do with that person? And that's where that conditional attendance policy I think becomes important. And so what are the kinds of things that would be in there? Obviously, you cannot work with minors in any capacity, any official capacity in the church. Number two: You are not going to be allowed to transport minors to or from—well, I'm going to take this kid home; he needs a ride, this seven-year-old. Uh, number three uh is what is what we call a chaperone policy: designating somebody who's going to be able to observe the person when he is on Church premises to make sure that uh inappropriate contact contact with minors cannot occur. We call it a chaperone. The person doesn't have to sit with this guy; I mean, just be able to observe the person. You may be 50 ft away in a sanctuary, but if that person gets up and walks out of the sanctuary, you follow him. Uh, one study showed that 77% of uh victims of child abuse in church occurred in in restrooms, so that's a high-risk area, and pedophiles know it. So uh that's another thing you got to have that chaperone and have that chain of custody where you never let this person out. Say there can't be any wrongdoing under those circumstances. Uh, and number three, number four I guess uh would be of course uh that the person should not be allowed to attend children or youth functions. And uh and I think it's important to point out that a single violation of these conditions should not lead to the church leadership practicing uh mercy and gra—well, what's just one wrong—it's uh one violation, big deal. It is a big deal. I I would have a zero tolerance policy because Jerry what you see sometimes is, you know, 15 or 10 polic or violations stack up. "Well, let's give them another chance," and uh that that is clear evidence in many cases of of negligence.

Let me mention just a couple other things. Uh, make sure you contact your Church insurance company to have them review your your conditions, your policy uh for their input. And uh and I think it's also very important to check with the individual's probation officer uh with regard to this policy that you've come up with, whether it's whether that person agrees to it or not. [Music] What we have done is we've used uh off-duty police officers and or Sheriff's uh office because they go through the proper training already. Okay, so we allowed them to actually act as our security officers. The other thing is once a licensed law officer pulls a gun, they're not operating on behalf of the church or themselves as an individual; they're operating as a police officer or as a law enforcement officer. And there are really uh there are four ways that the church could face liability in these cases: Number one is what is called the principle of premises liability, and we'll talk about each of these in a little more detail. The second one is uh a failure on a Church's part to hire or provide security guards. And number three is negligent selection of security guards by the church. And number four is liability for the negligent acts of those security personnel. So let's talk briefly about each one of these. Uh, the first one is premises liability, and and the basic principle here legally is this: that any property owner has a duty to protect persons who come onto his or her property from harm, uh, and and but generally that Duty does not extend to criminal acts. You have no duty to protect entrance onto your property from criminal activity unless it is foreseeable. Now what does that mean? Well, the the courts have really looked at a variety of factors in determining if prior criminal activity makes a a crime foreseeable on your premises. And let me mention three or four of those factors. The courts look to: Number one, were there previous crimes on your premises or close by? Number two, how similar were those crimes to the crime that occurred on your property? And number three, uh how recently did those other crimes occur? And number four, were those prior crimes publicized? I mean, if they happened four blocks away and it never was in the media, uh you didn't even know about it. There has to be some impartation of knowledge to church leadership that these other crimes did occur, which is not a problem if they happen on your premises, but obviously the farther away those crimes are from your property and the more dissimilar they are to the to the uh assault that happened on your property, the more unlikely it is that they're foreseeable, that that assault on your property is foreseeable. And as a result, you have no liability legally for the assault that occurred, and that's the bottom line. The fact is the vast majority of churches in this country are safe places that have never had an armed assailant injure or kill people uh or a similar act within a short distance from your church in recent memory. So the fact is, Under This legal doctrine of premises liability, most churches simply do not have a legal duty to provide armed security guards. Uh, again, that will depend on other similar violent criminal acts occurring on or near your property in recent months or maybe in the last few years. Did that did that occur? And was that knowledge imparted to you? Uh, only under those circumstances do you meet that foreseeability test. There have been many cases where this has happened; only a few have involved churches, but in every one a court concluded that the the uh there was no foreseeability because there were no similar crimes in recent history on or near Church premises. So there was no duty to provide armed security. Churches generally have no legal duty to provide armed security unless there is a foreseeability that somebody's going to enter onto Church premises and start trying to kill people. And now that that's not to say that can't happen; I'm sure it has. It would be true for some Churches in this country, but it would be a relatively I think uh small number or percentage of churches. So that's the uh but that's not to say a church should not have a security presence because apart from the legal Duty, which as I say in most cases, not all but in most cases is probably not required. Many churches view this as a theological or ethical Duty that we view as Christians, human beings as made in the image of God of infinite worth and value, and do they not deserve protection even if the risk is in fact unforeseeable or very low? Uh, the value of their life is so high, especially children, that maybe we should Implement uh protective measures. And I think that would explain in my own church why we do this, not because we feel we have a legal Duty because I believe that we do, but we believe there's a theological uh imperative involved here based on our understanding of scripture and of God's nature.

Now another basis for liability apart from the premises liability that requires foreseeability is uh a failure to hire security guards in the first place, and the two are kind of related, but generally there's no duty to hire security guards if there's not a foreseeable uh if if it's not foreseeable that you're going to have a violent criminal attacks on your premises. And there have been a number of cases where in involving secular businesses where the courts have said that—one famous case involved a California Supreme Court ruling where a shopping mall was sued by a female employee who was sexually assaulted by another employee, and uh she sued the mall Corporation and argued that uh it was negligent in not providing a security guard. And the Supreme Court of California said no security guard was needed because this type of behavior was simply not foreseeable uh in that facility. Uh, a third type of liability, Jerry, would be uh negligent selection of security guards by a church. So you could theoretically be liable even if you hire security if you were negligent or careless in selecting that person. So because there's such a wide range of competencies when it comes to security services, so this kind of thing requires that the the church exercise due care in the selection process. Is this a licensed security firm that you're using? Get references; you know, contact law enforcement; ask them about this security service. Or better yet, as Jerry mentioned before, is to hire on or off-duty uniform police officers as your security detail. That doing so has a number of advantages: Number one, the uniform itself is is a powerful deterrent, not to craz dis salant, but it is to a lot of people. Number two, police officers have extensive training, not just in the use of firearms, Yuri, but just as importantly in responding to emergency situations, which can overwhelm the average concealed weapons permit holder like myself. I I mean, you're just emotionally overwhelmed by the experience. And another advantage of using uh off or Duty police officers as your security contingent is they have continuing uh training; it's not just one-time course you took. And and I think most importantly, as you mentioned earlier, is a number of Courts have concluded that when a police officer is responding to a crime like an armed assailant, that person ceases to be your employee, your security guard, and becomes a public uh officer. So what that means is he or she is acting in the line of duty and is no longer acting as your agent or representative. So any question of negligence uh is deferred from you to the police officer and ultimately the police department. So uh that's another very important reason to use police officers as opposed to the private security service. And of course, when you're looking at concealed weapons permit holders, they would lack many of these characteristics of police officers. They don't become public officers when responding to a crime; they don't have continuing uh training on the use of firearms; they've had no experience or training on responding to em emergency uh crisis situations in the vast majority of cases, except for those that have prior law enforcement experience or maybe military. And as we said, some of these uh concealed weapons permit holders are going to have that additional component that I think makes them uh a more reasonable response, but short of that or in addition to that, I think using the police officer is an excellent idea. And then the fourth basis for liability in these cases, which we've alluded to, is liability for the acts of those security guards themselves. And here again is why it's so important to use uh police officers because when they're responding, if they shoot at that assailant and accidentally hit a bystander, uh they're acting in the line of duty; they become on duty. It is really it it elevates the risk from you and it transfers it to the police officer or to the the local government. And that's a very important component that doesn't apply when a concealed weapons permit holder that's had four hours of training starts shooting away at an armed assailant and hits members of the congregation. There absolutely can be liability on the part of the church for that collateral damage, uh, and that's why it's so important that uh if you're going to use concealed weapons permit holders as part of your security response, if you decide to do that, that you make sure they have that additional component beyond that normal permit uh to make them to establish I think their ability and competency to serve in that capacity. That can be prior law enforcement or military training; uh that can be additional training the church itself provides, as as your church does, Jerry. But those are the kinds of things you need to be thinking about. And of course, I also recommend that as part of your policy that you Benchmark your your practices. In other words, look at other facilities in your community, other comparably sized churches or secular entities that use security uh guards. What who are they using? How do you know uh are what are they doing with regard to concealed weapons permit holders? Find out what they're doing and Benchmark your practices to what other Charities are doing. That becomes your community standard on which you're going to be judged. If you fall below that level and thereby are deemed to be negligent. And of course, let me conclude by saying it's so important to have a legal review of your policy. Uh, your policy should be in writing, uh, and your security policy, and absolutely that should be reviewed and approved by legal counsel. I also recommend you have your local law enforcement uh check that out as well. You know, so really from using letting people use concealed carry people uh you know letting letting them operate as part of your church security team, really the church is picking up additional liability where here they thought they might be saving their people; the church is actually accepting more liability because they've let concealed carry people have the guns. If there is collateral damage from uh from an armed assailant, that's an excellent point. Why church leaders should take the risk of embezzlement seriously. Let me give you a little research of why church leaders should do this. The Gordon-Conwell Theological Seminary did some research through—

Its center for the study of global Christianity here's what they found: It is projected that ecclesiastical crime is projected to be $37 billion worldwide, or nearly 6% of the total givings of churches. In contrast, only $32 billion is spent on missions work to introduce Christianity to more people. So, if the way I look at this is that there's more money being going out the door from crime than what there is going out to missions. So, if we can just stop all of this crime, we can double the amount we do for missions, and and we can do the Lord's work twice as fast.

We use the term internal control in a technical sense, of course. It just means having proper oversight over the uh handling of cash, uh as well as church assets, and uh to ensure accountability. There are a number of things that can be done to ensure a competent system of internal control, which in turn will reduce greatly the risk of financial fraud. So we went over these last week. I'm going to mention them quickly again today, and you gentlemen both can comment on these if you can think of something we can we can you can say that will amplify these points.

So the first one—these are not in any order, by the way—uh the first one is, of course, to have more than one person count the church offering. I know what you're thinking: How could a church have one person count the offering? You know, Bob's back in that lock locked office every Sunday counting the—how is this possible? Let me tell you how it's possible. Church leaders don't want to offend people, and if we tell Bob, you know, we think there ought to be a second person counting that offering, you mean I've been doing this for 25 years by myself, and now you're accusing me of wrongo? And so churches church leaders recoil from that confrontation and allow Bob to continue uh counting that offering. So that's how it happens.

Uh, yeah, I think I think Rich, uh, you know, on a lot of these we're going to see a key concept is having multiple people involved. I think sometimes it's easy to think, you know, it'll streamline the process if we have one person count the offering and do the deposit and kind of kind of one person is kind of our go-to person, but it's a key concept here to have multiple people involved in the process. Sometimes that takes a little bit longer, and and it's a little more challenging to lead multiple people through those steps, but it always makes things safer. Yeah, it's what CPA's refer to as a division of responsibility, and by dividing responsibility you greatly ensure and contribute toward an internal control type of environment. You know, one of the things that I would say is that we should have have those the people that you have counting should both be unrelated. So number one, they're unrelated; not a husband and wife, not a husband and wife. Um, but then also rotate weekly, if you can, the counters of monies with different individuals, so you don't have the same person doing it every every week. So if you've got enough people in your church where you can do this, so if you have less money coming in all the time during one person counting, you're going to actually probably notice it, and they're going to notice it because of the division of duties.

Yeah, and that's the second point that I would make: having a pool of counters that you randomly rotate. And then the third point is uh making sure that at least two persons collect the offering. You say, well, how does that happen? Well, uh, in some churches that have balconies, uh, now think about this, uh you may have an usher up there, one usher sometimes collecting the offering and bringing those plates or bags down the stairway—that's isolated and unsupervised—down to the floor ultimately to the accounting room, and that money is unsupervised; it there's it's unaccountable for that period of time. And I know of a number of cases where people have in fact embezzled funds under those circumstances. So you want to have two people involved in counting and not just counting, but carrying offerings to the counting room. One of the things that a church can also do is actually have church envelopes for their members, and that way if people number one put cash in an envelope, it's not easily accessible to somebody that uh is in a balcony number one one number two; it also makes sure that people get the giving credit for that cash that they give.

Yes, and offering envelopes—let let me make an important point here—they are not legally required to substantiate contributions. Some—there's a widespread misconception—we've got to use offering envelopes uh or your contributions are not going to be tax deductible. That's nonsense; you don't need to use them, but there are reasons why you would want to. It does greatly reduce the risk of fraud; that's number one. Now let me mention some of the other ones we looked at last week, gentlemen. Offering counts are submitted to the person who deposits the offering; again, a different person should be counting and depositing the offerings. Uh, the next point, number five on my list, what we covered last week, uh the offering counts and bank deposit slips are not regularly reconciled. Sixth weakness would be only one signature needed to write a check. Most of the cases of church investment that I uh that I have reviewed, out of dozens, scores of them, uh most of them come, I would say a lot of them, maybe not most, come down to this one point: sole signatory authority on the church checking account. And I'm not opposed to a church maybe having sole signature authority uh for one person for for for uh checks of up to a certain amount, but I would make that a very low amount; in fact, I'm opposed to it in general, right. Um, and uh I know some churches make it—get checks above 500 or below 500 don't have to have a second signature. I don't agree with that. So uh but having a second signature to me it's one of the fundamental postulates of internal control. One of the things that I'll just follow up on that—have your signature card at the bank also, that if you have a a certain amount, like it requires two signatures to have any check over $100, that that signature card is on at the bank, so the bank does know that that requirement is in place.

Yes, and here I might bring up another point, and that is the the the risk of using digital signatures or signature stamps. Many churches use them, and there have been cases of embezzlement. We talked about one last month where an individual embezzled hundreds of thousands of dollars from his church; he was a financial uh volunteer or or employee actually, and uh he was able to have unrestricted access to digital signatures of all the officers of the church, and he was able to increase the church's line of credit, ultimately leading to misappropriation of funds of close to a million dollars. Uh, so if you use digital signatures or or signature stamps, just be aware that that is a major uh risk that you that you encounter. Any comments, gentlemen? No? Go ahead. Members—yeah, we talked about offering envelopes. Um, contribution receipts are not issued to members. Most churches, I think, do issue contribution receipts quarterly, semiannually, sometimes annually. Those are very important, and it's very important for you to encourage church members, donors, to examine those receipts from the church. This is the church's records, and if your records don't correspond to that to that—if if you have records of donations uh of greater than what the church's receipt is showing—that's a that's a red flag right there of potential mis misappropriation of church funds. So encourage people to look for discrepancies and to report them to church leadership. Another weakness in internal control is offerings are not deposited immediately. Obviously, offering should be deposited promptly. With—I would also say have the checks stamped for deposit only once you get them, so have somebody stamp them for deposit only, so they can only go into the church's bank. That's good. We mentioned that last last time, last month. Uh, monthly bank statements are not reviewed by someone having, you know, responsibility for handling cash; that's another weakness in internal control. Obviously, you want to have those statements reviewed by an employee or church officer having no responsibility for handling cash or issuing checks. And then my last one, number 11, was uh that we mentioned last week, uh making sure that you do not reimburse employees uh expenses without adequate substantiation. This is another major source of financial crimes within churches; is uh churches or church officers sometimes writing checks to themselves for things that have not been properly uh accounted for in terms of business purpose. And we mentioned last week the the related issue of uh pastors sometimes thinking that they have been underpaid, and many times they have been because of the economic climate, maybe a downturn in contributions, maybe what the church authorized for salary the church was unwilling to pay, and so over a number of years a pastor will just start writing checks to him or herself uh so that I get what I deserve. Well, that may be what you deserve, but that can be a very serious uh matter, and this this relates again to this issue of making sure that that reimbursements from the church are for properly accounted for expenditures that have been authorized by the board.

One of the couple more things uh I would have the counting uh that we mentioned last time—counting should be done behind a locked door when they're doing the offerings—and it's great to have a camera overlooking the counting area as long as the people know that there is a camera in the room. Yeah, there was a case in California, I think we mentioned briefly last time, where a church was actually found liable for having a secret camera in the counting room uh where they were looking for the perpetrator of what they perceived to be embezzlement of church funds, and and the court said this was likely an invasion of privacy, which is intruding upon the seclusion of an individual uh in a way that would be would kind of shock the conscience. And and so the point is let people be aware that just like in a bank lobby you see the cameras all over the place, and that's just as much a deterrent as trying to hide that camera somewhere where the person can't see it, because if that's what you're going to do to try to catch the person, you run the risk of personal liability for the church for invasion of privacy. You know, Rich, I think uh the the other angle on that too is you—we have a camera in our counting room, and we use multiple teams; we do a lot of these controls uh we've talked about with regard to the offering, and sometimes when you first put those things in place the counters can say, what, do you not trust me? Well, it's as much of a factor of protecting the counter and the people that are involved as it is protecting the church's funds, because if something were to come up missing, you know, it protects those individuals that are involved to be able to say clearly it wasn't it wasn't Bob in the offering room because Bob has some accountability in place and we can verify that Bob is in the clear, uh kind of using that example for—just like having a video in the nursery, we've talked about this in other presentations—just wonderful forensic evidence to to explain why a toddler has suspicious bruises. Uh, was that child molestation? Well, if you have a video you can replay and you can see the child fell off a stool, uh you know that then you you can completely uh eliminate the potential of abuse. Oh.