Toward a Spirituality of Compliance

John C. Peiffer II
President and General Counsel
Napa Legal Institute
While an apostolate’s noncompliance could harm the organization’s ability to operate or attract donors, the more spiritually significant concern is that such noncompliance could actually rise to the level of scandal, which could distract from – or even prevent – the witness of the apostolate and its staff or volunteers through whatever good work they do. Faithful completion of the most mundane tasks, even legal compliance, is the stuff of saints!
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Bottom Line:  

  • Compliance can often seem tedious, but for a faith-based organization, compliance is an opportunity to offer up inconveniences and serve faithfully in all matters, great and small.  
  • An apostolate’s legal and tax compliance demonstrates its love of neighbor.
  • While an apostolate’s noncompliance could harm the organization’s ability to operate or attract donors, the more spiritually significant concern is that such noncompliance could actually rise to the level of scandal, which could distract from – or even prevent – the witness of the apostolate and its staff or volunteers through whatever good work they do.
  • Faithful completion of the most mundane tasks, even legal compliance, is the stuff of saints!

In presentations about Napa Legal, I often joke that we are focused on the “boring stuff” facing religious nonprofits – the tedious (and sometimes overwhelming) maze of federal and state laws, administrative rules, local ordinances, registrations, and filings that must be navigated to operate a compliant tax-exempt organization.  When I hear from apostolate leaders about a missed filing deadline, botched conflict transaction approval, or failure to have formal board meetings or keep minutes, a typical rationalization is that the organization was so focused on mission fulfillment that staff had neither the time nor the resources to address the so-called “boring stuff”.  

The problem with this approach and rationalization is that such noncompliance (which is a form of mismanagement) can lead to loss of tax-exempt status, loss of accreditation, loss of credibility, and other existential threats to continuation of the mission.  In extreme cases of alleged compliance failures, an organization and its leadership could find themselves defending against involuntary dissolution.

Although the practical risks of non-compliance necessitate compliance, I realize that this may not be sufficient motivation for enduring the tedium of paperwork and other administrative responsibilities required to maintain compliance.  Apostolates (and those who work or volunteer for them) are founded upon and directed toward supernatural ends, such as corporal or spiritual works of mercy, evangelization, and the pursuit of personal holiness.  I would suggest that there are supernatural reasons for ensuring that your apostolate remains in compliance, as well, giving rise to a “spirituality of compliance”.

There are any number of sources from Sacred Scripture and Tradition that one could use to articulate a spirituality of compliance.  I will highlight three in this blog post.

1. The Fourth Commandment

The Catechism of the Catholic Church (CCC) discusses the duties of citizens to the civil authorities under the heading of the Fourth Commandment, “Honor your father and your mother,” which is itself under the heading of Christ’s second commandment, “You shall love your neighbor as yourself.”  The Catechism explains that “[s]ubmission to legitimate authorities and service to the common good require citizens to fulfill their roles in the life of the political community” (no. 2239).

This teaching also derives from Our Lord’s response to the question regarding the payment of taxes to Caesar: “Render […] to Caesar the things that are Caesar’s, and to God the things that are God’s” (Matthew 22:21).  While we are obliged not to comply with immoral or unjust dictates (cf. CCC no. 2242; St. John Chrysostom, Homily 70 on Matthew: “[W]hen you hear, Render unto Cæsar the things which are Cæsar’s, know that He is speaking only of those things, which are no detriment to godliness; since if it be any such thing as this, such a thing is no longer Cæsar’s tribute, but the devil’s”), we also are obliged to comply with those requirements that are not immoral or unjust.    

As St. Paul admonishes: “Let every person be subject to the governing authorities.  For there is no authority except from God, and those that exist have been instituted by God.  Therefore he who resists the authorities resists what God has appointed, and those who resist will incur judgment.  For rulers are not a terror to good conduct, but to bad.  Would you have no fear of him who is in authority?  Then do what is good, and you will receive his approval, for he is God’s servant for your good.  But if you do wrong, be afraid, for he does not bear the sword in vain; he is the servant of God to execute his wrath on the wrongdoer.  Therefore one must be subject, not only to avoid God’s wrath but also for the sake of conscience.  For the same reason you also pay taxes, for the authorities are ministers of God, attending to this very thing.  Pay all of them their dues, taxes to whom taxes are due, revenue to whom revenue is due, respect to whom respect is due, honor to whom honor is due” (Romans 13:7; emphasis added; see also, CCC 2240).

Commenting on this passage, Chrysostom points out that, “to show that these regulations are for all, even for priests, and monks, and not for men of secular occupations only, [St. Paul] has made this plain at the outset, by saying as follows: ‘let every soul be subject’ [...]” (Homily 23 on Romans).  

This is a pretty clear response to those who would say they can’t focus on compliance issues because they are too focused on their apostolate.  There is no exception from the moral obligation to comply with governmental requirements because one is doing apostolate.  Although the Catechism refers to the obligations of individual citizens, it doesn’t take an extraordinary leap of reasoning to see why apostolates, which are the apostolic fruit of collaboration among citizens, also should meet these obligations.

Bottom line: An apostolate’s legal and tax compliance demonstrates its love of neighbor.

2. The Great Commission

I am sure that most of us can quote the end of St. Matthew’s Gospel: “Go therefore and make disciples of all nations […]” (Matthew 28:18), Our Lord’s “great commission” before His Ascension.  While the Church and her pastors have unique responsibilities with respect to evangelization, as Pope Paul VI observed, “[t]he command to the Twelve to go out and proclaim the Good News is also valid for all Christians, though in a different way. […] Those who have received the Good News and who have been gathered by it into the community of salvation can and must communicate and spread it” (Evangelii Nuntiandi (EV), no. 13).  

While each of us will have opportunities to offer a verbal witness of the faith at times, we cannot avoid the reality that our actions, the manner in which we live our faith, generally will speak louder than our words.  

“Above all the Gospel must be proclaimed by witness.  Take a Christian or a handful of Christians who, in the midst of their own community, show their capacity for understanding and acceptance, their sharing of life and destiny with other people, their solidarity with the efforts of all for whatever is noble and good.  Let us suppose that, in addition, they radiate in an altogether simple and unaffected way their faith in values that go beyond current values, and their hope in something that is not seen and that one would not dare to imagine.  Through this wordless witness these Christians stir up irresistible questions in the hearts of those who see how they live […]” (EV no. 21).  

Similarly, in the Letter to Diognetus, an early work of Christian apologetics, the author describes Christians as displaying to the world “a wonderful and confessedly striking method of life”, which includes “obey[ing] the prescribed laws, and at the same time surpass[ing] the laws by their lives.”  For the author of the Letter, the extent to which Christians (who were, at the time, a persecuted religious minority) complied with, and even exceeded, the demands of the civil law was a witness in itself, an example of their method of life.

Just as compliance with the law can serve as a positive witness, so too can noncompliance have the opposite effect.  Although an apostolate may be doing great work in the area of service of the poor, evangelization, defense of the freedom of religion and freedom of conscience, or any number of other endeavors, lapses in compliance can undermine the impact of such work or even become a cause for scandal in some circumstances.  As the Catechism explains, “[s]candal takes on a particular gravity by reason of the authority of those who cause it or the weakness of those who are scandalized.  It prompted our Lord to utter this curse: ‘Whoever causes one of these little ones who believe in me to sin, it would be better for him to have a great millstone fastened round his neck and to be drowned in the depth of the sea.’  Scandal is grave when given by those who by nature or office are obliged to teach and educate others” (no. 2285).  

Bottom line: While an apostolate’s noncompliance could harm the organization’s ability to operate or attract donors, the more spiritually significant concern is that such noncompliance could actually rise to the level of scandal, which could distract from – or even prevent – the witness of the apostolate and its staff or volunteers through whatever good work they do.  

The Little Way  

The last source I would point to as foundational to a spirituality of compliance is St. Therese of Lisieux, who, in simple but profound words, articulated her “little way” of pursuing sanctity through “spiritual childhood”.  

Commenting on her own spiritual resolutions during the period immediately before entering the Carmelite monastery, St. Therese explains, “I resolved to lead a life of greater devoutness and mortification than ever before.  When I speak of mortification, I don’t mean the kind of penance practiced by saints.  There are great souls who practice every sort of mortification from childhood, but I am not like them.  All I did was to break my self-will, check a hasty reply, and do little kindnesses without making a fuss about them – and lots of other similar things.”  

For many, perhaps most, attending to compliance issues, such as annual filings, conflict of interest or compensation approval procedures, and the like, are “boring” distractions from the “real” work of the apostolate.  

To those who would prefer not to do these things, I would say, “Offer it up!”  Careful and timely attention to these matters present an opportunity to mortify ourselves in the manner St. Therese identifies.  Through such mundane tasks, we can offer a “little sacrifice” of love to God.  

As Pope John Paul II so beautifully explained in his apostolic letter declaring St. Therese a doctor of the church, “Through spiritual childhood one experiences that everything comes from God, returns to him and abides in him, for the salvation of all, in a mystery of merciful love.”

But practically speaking, how does one do this?  Before you begin one of these compliance tasks, for example an annual report to be filed with the state in which your apostolate is registered, take a brief moment to pray, offering this little task that you are about to complete to God as a little sacrifice for some intention, such as the success of your apostolate, the intentions of the Pope or your bishop or someone served by your apostolate, a donor or volunteer, or a colleague.  This simple act of making the task itself an oblation to God can make the supernatural dimension of these mundane tasks more apparent.  

Bottom line: Faithful completion of the most mundane tasks, even legal compliance, is the stuff of saints!

Concluding thoughts

As the Fathers of the Second Vatican Council affirmed, “[A]ll the faithful, whatever their condition or state, are called by the Lord, each in his own way, to that perfect holiness whereby the Father Himself is perfect” (Lumen Gentium no. 11).  For those of us involved in leading and administering apostolates, one of the means available for us to pursue our own sanctity is through the legal compliance that is required for our apostolates to continue operating in good standing.  Through our compliance, we fulfill the commandments, provide a faithful witness to the world, and make an offering to God.

May God richly reward our apostolates for these little sacrifices!