Standards

St. Charles Borromeo Seminary

Self Accreditation Requirements

Who We Are

St. Charles Borromeo Seminary is an integral component specified under the Charter of Operations and Bylaws of the United Episcopal Catholic Communion. The United Episcopal Catholic Communion is formed under the laws of the United States of America IRS Code 26 (508) (508c1a which is a 501c3 component with code specified exemptions) and under Missouri Statute Section 355, RSMo. This organization operates as a Faith Based Organization under stated statutes and are recognized under the precepts inherent in the Hague Convention worldwide.

MO§ 173.616. Schools and courses that are exempt from sections 173.600 to 173.618. The following is a list of the types of institutions and training programs that may be eligible for exemption from the requirements of the Proprietary School Certification Program.  For details regarding exemption criteria, please see Section 173.616, RSMo:

• Missouri public institutions

• Missouri colleges or universities represented on the Presidential Advisory Committee as provided in subsection 2 of section 173.005

• Missouri approved private institutions as defined per subdivision (2) of section 173.1102

• Not-for-profit religious institutions accredited by the American Association of Bible Colleges, the Association of Theological Schools in the United States and Canada, or a regional accrediting association, such as the Higher Learning Commission of the North Central Association, which is recognized by the Council on Postsecondary Accreditation and the U.S. Department of Education

• Not-for-profit religious institutions offering only religiously designated degrees and programs

• Charitable institutions that provide instruction without financial charge

• Schools offering only non-vocational or recreational courses or programs

• Employer sponsored instruction or training available only to employees

• Training by restricted membership trade or professional associations for members only

• Schools or training programs regulated and approved by other state agencies

• Elementary and/or secondary schools (i.e., schools enrolling students primarily under the age of 16)

The St. Charles Borromeo Seminary does not operate as an independent entity. As an integral component of the parent church, the operations are inseparable. This has precedence over the centuries of church operations regarding missions and monasteries as integral components inseparable from the parent organization. We herein state clearly that the parent church and the seminary are one cohesive entity.

St. Charles Borromeo Seminary in current state is a non-accredited institution with the specific mission to train clergy for our specific organization in aspects of theology, divinity, biblical history, teachings of the church fathers, search for faith, church formation, proper dress and sanctuary protocols, monastic practices, sermon/homily design and presentation, ethics, religious philosophy, morality, shepherding and outreach.

This organization does not claim, real or imagined, that the training is designed for any organization outside of the parent church or associated organizations. Within the Independent Churches, if one so desires to recognize our training precepts, it is their right to recognize this organization.

Under the laws of the United States of America and the State of Missouri the St. Charles Borromeo Seminary offers degrees of ‘Theological Nature Only’. Under legal precedence in the United States this practice is beyond refute.

Details regarding the non-accredited status of seminaries in the United States and also various States will be presented in the appendix. There are critical issues regarding private, regional or nation accreditation associations. Those issues will also be presented in the appendix.

Within the context of declaring St. Charles Borromeo Seminary, hence forthcalled ‘seminary’ we hereby present our self examination practices for credibility and success.

Before we declare our ‘internal accreditation/examination’ process we must herein define the seminary outcome. It is stated that the seminary assists individuals with a learning process so they may reach the potential of their faith and apply that to church operations and hence bring the word of biblical text, and the solace of the church, to the people in a meaningful manner. This institution does not, real or imagined, train theologians.

Definition of priest (clergy):

An ordained clergy of the Catholic, Orthodox, Anglican or other Christian Church having the authority to perform certain rites and administer certain sacraments.

Definition of Theologian:

Theologians study and debate the idiosyncrasies and minutia of the workings of religion. Theologians examine the human experience of faith, and how different people and cultures express it. Theologians examine the many different religions of the world and their impact on society.

Why are these definitions critical? For over 1500 years of history, Christian individuals did not attend universities in order to become practicing clergy. Practicing priests generally had their training in a monastic environment. A large portion of priests received their training via an apprenticeship with a knowledgeable parish priest. Even though universities existed from the earliest time of Christianity, it was the purview of theologians or ranking church members (bishops and above) to attend universities. University training did not become quasi available until the Roman Catholic Church began the ‘counter reformation’ during and after the Council of Trent. ¹

One example of this was the priesthood of Martin Luther. In 1507, Luther was ordained to the priesthood by Bishop Jerome Schultz. Luther did not earn his bachelor's degree in biblical studies until March 9, 1508. ² Hence, he was a practicing priest long before he held a religious degree. Once he achieved higher degrees, he then became a professor of ‘biblia’. The previous statement is of great consequence, Luther was a priest BEFORE university training in religion.

The accreditation system in American higher education began in the late 1800s and early 1900s as a way for colleges and universities with high academic standards to distinguish themselves from institutions that had curricula based on the primary education model. ³

Accreditation was a ‘voluntary’ process until 1944. The GI Bill of that era allowed veterans to use federal funds for a college of their choice. After an initial attempt to allow states to generate a list of ‘approved’ colleges, the issue of corruption in the process was raised and affected the release of federal funds. The Federal Government did not process a law until 1952 to create a federal system of accepted accreditation agencies. ⁴

If this is put into perspective, accreditation of ‘seminaries’ did not exist for nearly 1900 years in Christian history.

By the historical facts surrounding monastic seminaries versus universities, we as an organization embrace 1500 to 1800 years of our preceding church fathers training precepts. The St. Charles Borromeo Seminary trains clergy to bring the solace of the church to the masses and NOT theologians.

So let us now proceed into our standards and self examination.

The seminary respects the need for standards. That comment not withstanding there is a major difference in how standards should be handled with respect to accredited and non-accredited seminaries. One aspect that is critical to understand from the start: Accredited Seminaries operate ‘as a business’ in most respects and large sums of money change hands. It is not unusual for an accredited seminary to charge $650.00 U.S dollars or more per credit for any degree level.

It is herein declared that the St. Borromeo Seminary is tuition free. It is integral to the church and operates as part of the parent church. The operations are based on a Free Will Tithe, that is a decision to be made by the requestor (detailed below). The tithe is made to the parent church, of free will, and is not to be construed as payment for a service, real or imagined. Therefore, there is no implied contract or agreement, real or imagined.

It is hereby declared another difference exists between the non-accredited format of the St. Charles Borromeo Seminary that departs from the more secular, political and monetary based accredited seminaries. We declare that for clergy to build their faith, that process does not end with the seminary training. Faith building and the understanding of the divine must continue for the rest of their natural lives, or disenfranchisement from the clergy. Any independent church organization may require continued studies for their clergy as specified by their superiors. This also extends to the length of calendar and clock time required for a seminarian to reach their potential. Our curriculum is designed so that a seminarian can progress through the materials and hands on training at a pace conducive to their secular life and general learning capacity. This ‘formation’ process is a variable accredited seminaries rarely take into account.

Moving on, the decision was made to use a rough outline based on the standards set down by the Association of Theological Schools. Herein we will list the outline of the standards for the self examination of the St. Charles Borromeo Seminary.

Standards of the St. Borromeo Seminary

Legal Authorization:

MO§ 173.616. Schools and courses that are exempt from sections 173.600 to 173.618. The following is a list of the types of institutions and training programs that may be eligible for exemption from the requirements of the Proprietary School Certification Program.  For details regarding exemption criteria, please see Section 173.616, RSMo:

Not-for-profit religious institutions offering only religiously designated degrees and programs

Mission:

The mission of the seminary is to provide a faith community, based on the standards of the Faith Based Organization as supported by the laws of the United States, the statutes of the state of Missouri and operate under the precepts of supporting clauses of the Hague Convention.

The seminary provides the necessary training to allow clergy to operate under the canons, rubrics, beliefs and ethical guidelines of the parent organization and associated elements. There is no claim, real or imagined, that this training fits any need within other organizations. We do declare, that if approached to use the seminary for their needs, it is done so as a free will effort with no guarantees, real or imagined, that the requesting organizations goals will be met.

We do declare that the processes, procedures and standards are the sole property of the United Episcopal Catholic Communion and the integral St. Charles Borromeo Seminary and the Coalition of Independent Christian Seminaries. It is agreed in principle that the processes, procedures and standards will be utilized of free will, with no claim of warranty real or implied. It is fully understood that the processes, procedures and standards are designed to elevate credibility and unity within the organizations that may desire to use them.

The seminary has the mission to train clergy in the necessary faith, biblical studies, history of the church and church fathers, utilization of the faith in their ministries and provide core ethics guidelines. The seminary training is bound by the canons, rubrics, ethics, and beliefs of the parent organization. We do declare that the previous declaration may not match the requirements of the myriad of Christian organizations and sects.

Integrity:

The integrity of this seminary is based on the needs of the parent church; canons, rubrics, ethics and beliefs. We will act with integrity in our dealings with all seminarians and also with the general public. Christian ethics dictates that we treat all seminarians with honor and respect. We decry any form of discrimination based on race, creed, color, national origin, sexual persuasion or orientation.

This organization will follow all applicable laws and statutes as specified in the United States and the state of Missouri. Whereas the seminary is integrated into the parent church, is monastic in nature and does NOT purport to serve any other organization, there are limited regulations to dictate operation.

This seminary will report directly to the Bishop’s Council of the parent church, and will be evaluated by it’s ecclesiastical peers.

The integrity of this institution is based on biblical principles and theological methodology. These principles outweigh any secular university (seminary) principles of collegiate learning. The methodologies of both biblical and systematic theology are embraced.

Learning and Formation:

The following standards are supported at all degree levels

This institution does not subscribe to ‘academic rigor’. Academic rigor has little place in faith or divine studies. We agree that the seminarians must be challenged, that not withstanding they must be challenged at a level they can handle and comprehend. Academic rigor is most often directed at book learning and rote memorization. Christian faith cannot be memorized. Faith must be FELT, it must be in the HEART, it must manifest itself in the SOUL. Every individual is UNIQUE in their relationship with the DIVINE.

Within that context, we place the appropriate learning tools and materials within reach of each individual. They can proceed with the ‘rigor’ that best suits the compromise between the requirements of their secular life and religious life.

Within the context of formation as defined:

Christian spiritual formation is the process of being conformed to the image of Jesus Christ for the glory of God and for the sake of others.

This process is personal and we strive to assist each seminarian with this formation by requiring non-learning activities; prayer, meditation, reflection, one on one discussions, direct mentorship, practicing monastic precepts, requiring the recitation of the Offices and other self-aware/god-aware activities.

While all learning has a finite pedagogy, as in the presentation of training materials and evaluating the understanding of the seminarian by written and oral interrogation, we fully realize that the search for the divine has unique characteristics that cannot be taught. A certain amount of faith must be found within EACH INDIVIDUAL, on there own in their relationship with GOD. This seminary recognizes the fluidity of the understanding of theology and divinity, and that there are as many interpretations as there are theologians. We embrace theological difference as part of the curriculum, and encourage controlled debate and free thought.

The shepherds (we do not subscribe to the term teaches, trainers, professors or other secular terms. Generally, we view the terms as being inappropriate) are Bishops in good standing of this organization. They have demonstrated their understanding of theology, divinity and church operation not only by their ‘studies’ but also by their actions as priests of the organization, their recognition by the Patriarch and Presiding Archbishop of the parent church and by the Chancellor of the seminary. The greatest amount of of learning for any priest is by practicing and observing others practice the faith.

We support and require interactions with the seminarians, including personal communication, discussions on lessons, evaluating the work, evaluation of hands on training and much more.

Academic Quality Accreditation:

We declare that this institution bears the responsibility of accreditation upon itself. Both secular and religious accreditation agencies use a university academic model that is not conducive to the needs of the church or religious studies.

The academic quality is based on rigorous courses set down by Thirdmill and created by some of the finish clergy from around the world. The courses and programs are listed under ‘Degrees’ below. All course content and material is listed.

The hours of study are based on credits. The number of study hours based on the credits per module is a variable as this institution allows seminarians to study at their own pace.

Course delivery is based on self study from the module, written essays on each individuals personal understanding of the material and open questioning by the training staff. The teaching methodology is based on this principle, whereas each seminarian must be allowed to find their faith within the context of their personal understanding of the divine.

Guidance by the training staff (bishops, shepherds) is ongoing as required.

The bishops delivering the training are theologians in their own right.

Assessment per credit is based on assigned points. The evaluation MUST be subjective in nature. Whereas each individual will find their faith in and understanding of the divine at different levels, finite academic rigor has no place in theological studies.

Upon completion of a degree level, each individual will receive a Certificate certifying their degree level. Each individual will also receive a transcript of their coursework points/credits.

Accreditation, recognition and references:

This organization operates under self accreditation principles. We operate under the laws of the state of Missouri: MO § 173.616. Schools and courses that are exempt from sections 173.600 to 173.618.

The recognition of this organization is in the purview of the Lord Jesus Christ, biblical text and historical tradition of the church universal. Therefore, any references must be based on biblical text or the Bishop’s Consistory of the parent church.

Educational values and ethics:

All educational values are based on the principles of biblical and systematic theology as set down by theologians worldwide. The ethics of the seminary are strictly and securely bound in Christian Ethics based on biblical foundations. The ethics document is displayed on the parent church website or made available on a separate document.

Quality Control

All course materials are updated as they become available from Thirdmill. The seminary will accept all comments and suggestions from the seminarians regarding their experience. 

All processes, procedure, standards or training materials specific to SCBS will be evaluated and updated as required. All changes to SCBS specific documentation is reserved in whole by the Patriarch of the United Episcopal Catholic Communion and the integral St. Charles Borromeo Seminary.

Library:

The seminary, along with a secondary source, maintains a research library in excess of 5,000 documents. The library is accessible free with no restrictions. The entire library is supported online.

Faculty: (Shepherds)

The qualification of the faculty is determined not by the ‘degree’ level of an individual shepherd, rather by their experience with God and the public by participation in the faith. This experience far outweighs other types of learning, as practicing the faith brings one closer to the faith.

To be clear, teaching and learning in the realm of faith can be a matter of someone sharing their real world experiences in the faith. This process is REQUIRED for anyone who may wish to shepherd a seminarian.

Governance:

The governance is under the absolute control and purview of the Presiding Archbishop of the parent church, who is also the Chancellor (Rector) of the seminary. Whereas the learning process is not totally in the realm of book learning or ‘hands on’, the governance must take into account the spiritual aspect. Spirituality must be discussed and shown by actions, not something easily discussed in text.

The Chancellor has unrestricted authority over all aspects of the seminary.

Degrees:

Bachelor of Sacred Christian Theology

120 Points (Credits)

Coursework is designed to prepare the seminarian for immediate installment as clergy in the parent church. This may include deacon, licensed minister or priest depending on evaluation by the Presiding Archbishop.

The main theology of the Christian Faith based directly on the following biblical studies:

01. The Apostles Creed – 6 modules, 20 credits

02. The Gospels – 5 modules, 19 credits

03. The Book of Acts – 3 modules, 12 credits

04. We Believe in God – 4 modules, 13 credits

05. We Believe in the Holy Spirit - 4 modules, 13 credits

06. We Believe in Jesus – 5 modules, 19 credits

07. Building Your Theology – 4 modules, 13 credits

The following are required for all levels of study (bachelors and masters, must show proof of completion.

1 Point (Credit)

1. Altar Guild

2. Consecration of an Altar

3. Consecration of a Church and Altar

4. Consecration of Gregorian Holy Water

5. Consecration of Holy Water

6. Liturgical Colors

7. Offices (Video once every two weeks required. https://universalis.com/)

8. Ethical Guidelines

9. Vesting Prayers

10. Homiletics 1 through 5

10a. Produce a minimum of 4 sermons after homiletics training and provide cell phone/computer video for evaluation. (Keep sermons to approximately 4-5 minutes)

11. Prepare and present two full religious services from the accepted liturgies (Holy Communion may or may not be requested) and provide cell phone/computer video for evaluation.

The seminarian must choose either the Independent Catholic Option or the Anglican Option. That option is required for the bachelors only and must show proof of completion, but carry no point (credit) weight.

Anglican Studies (Option 1) (1 point/credit)

1. 39 Articles of the Anglican Faith

2. An Explanation and Guide to Anglicanism

3. Anglican Belief and Practice

4. Anglican Doctrine

5. Anglican Theology

6. Anglican History

7. Anglican Vestments

8. Apostolic Tradition by Hippolytus

9. Articles of Religion

10. Generous Love

Old Catholic Studies (Option 2) (1 point/credit)

1. About the Utrechter Union (Old Catholic) (From the Utrechter Website)

The Nature of the Church and its Mission

Unity, Catholicity and Apostolicity of the Church

Ministry and Leadership

Supralocal and universal koinonia of the Church

Unity in Diversity

2. Altar Servers Step by Step Guide

3. Apostolic Tradition - Hippolytus

4. Catholic Vestments

5. Liturgical Colors

6. Main Requisites for the Mass

7. Old Catholic Church History

8. Postures at Mass Version 1

9. Postures at Mass Version 2

10. Postures at Latin Mass

Required Training Videos (Option #1 - Anglican Studies) (1 credits)

Anglican Studies

1. Anglican Mass 1 - YouTube

2. Anglican Mass 2 - YouTube

3. Chanted 1928 Mass - YouTube

Required Training Videos (Option #2 - Old Catholic Studies) (1 credits)

Old Catholic Studies - Novus Ordo

1. Novus Ordo - Draw Near - YouTube

2. Novus Ordo - Diocese of Wichita - YouTube

3. Novus Ordo Explained - YouTube

4, Novus Ordo - Holy Trinity - YouTube

Old Catholic Studies - Latin Mass (Tridentine)(For study of postures and pomp, no latin required)

1. Latin Mass - Goettler - YouTube

2. Latin Mass Series - FSSB - Videos 1 to 20

Essay and Final Thesis (8 credits total – Essay 2 credits, Thesis 6 credits)

Master of Sacred Christian Theology

40 Points (Credits)

Coursework is designed to prepare the seminarian for immediate installment as clergy in the parent church. This may include deacon, licensed minister or priest depending on evaluation by the Presiding Archbishop.

The main theology of the Christian Faith based directly on the following biblical studies:

100. Kingdom, Covenants and Canon of the Old Testament - 4 modules, 4 credits

101. Kingdom and Covenant in the New Testament - 3 modules, 3 credits

102. The Heart of Paul's Theology - 4 modules, 4 credits

103. Paul's Prison Epistles - 5 modules, 5 credits

104. The Book of Joshua - 4 modules, 4 credits

105. The Epistle of James - 2 modules, 2 credits

106. The Book of Hebrews - 2 modules, 2 credits

See the section above under bachelors: The following are required for all levels of study (bachelors and masters, must show proof of completion. (3 Credits)

Essay 1,2 and Final Thesis (8 credits total – Essay1 3 credits, Essay2 3 credits, Thesis 7 credits)

Doctor of Sacred Christian Theology

60 Points (Credits)

Coursework is designed to prepare the seminarian for immediate installment as clergy in the parent church. This may include deacon, licensed minister or priest depending on evaluation by the Presiding Archbishop.

The main theology of the Christian Faith based directly on the following biblical studies:

200. He Gave Us Scripture - 11 modules, 12 credits

201. What is Man - 4 modules, 6 credits

202. Your Kingdom Come, The Doctrine of Eschatology - 4 modules, 6 credits

203. Making Biblical Decisions - 10 modules, 12 credits

204. He Gave Us Prophets - 8 modules, 10 credits

205. Christian Ethics - 1 Module, 6 credits

Essay and Final Thesis (8 credits total – Essay 2 credits, Thesis 6 credits)

Evaluation:

Evaluation of faith is not easily quantified. Our standards dictate that textbook learning, rote memory regurgitation and subsequent finite question and answer evaluation does not and cannot take into account the depth of ones personal faith, comprehension of the divine or how to present that faith to the subsequent church memberships the clergy serves.

The evaluation policy is based on the precepts of the following:

• All lessons require a written response (essay) of a word count with a set minimum, and presented for evaluations by a member of the Bishop’s Council. The essay consists of the perception of the knowledge gained by the seminarian regarding the content of the learning module.

• Each essay is analyzed in the same manner as any collegiate essay. The essay is evaluated for theological accuracy, integrity of personal interpretation of the content, logic, ethical bearing, context, grammar and faith characteristics. Points (credits) are assigned to each learning module, and evaluated in 1/10 point increments based on evaluation of the criteria listed herein.

• Random questions regarding a module may be presented at any time by any of the Bishops. The question must be submitted in essay form with a set word count minimum. The evaluation is the same as listed previously.

• Outside of the learning modules, the seminarians are required to complete a complex essay of a minimum word count discussing their personal faith and religious beliefs, based on YOUR feelings and opinions, not the opinions of teachers you have learned from. The evaluation is the same as listed previously.

• The seminarian will be required to create a research document of a minimum word count, using their own resources, on a random subject of Christianity as specified by the Bishop. The must provide all supporting document references as footnotes (for validation). The evaluation is the same as listed previously.

• The seminarian, when completed with all modules and essays, is required to submit a thesis of a minimum word count in the breadth of the course of study. The evaluation is the same as listed previously.

• The seminarian will be required to study, and possibly comment via essays, the process of various activities a clergy performs in normal practice. Many aspects of this process may be hands on, and must be observed by some means by the attending Bishop. The evaluation is the same as listed previously.

• The seminarians will be required to view, and possibly comment on via essays, a series of How to Videos of clergy activities (example: Performing Mass). The evaluation is the same as listed previously.

• For all evaluations, we state clearly that all aspects of Christian training has a fair amount of subjectivity by definition. This truth is self evident; denominational differences are the proof that religion can be very subjective. We strive to embrace that subjectivity as long as it does not conflict with the canons, rubrics, beliefs or ethics set down by the parent church.

  • This organization reserves the right, based on this statement of subjectivity, to change evaluation processes on an ‘as needed’ basis. This includes minor ‘tweaks’ to the curriculum. This flexibility MUST exist as there may be specific cultural, ethnic, secular or other needs that may be met for a specific congregational entity. This process we subscribe to as long as it does not conflict with the canons, rubrics, beliefs or ethics set down by the parent church.

Certificates:

Certificates are presented upon successful completion of the degree level. The degree designations are Th.B, Th.M and Th.D. These degrees by law are of ‘theological nature’ only.

The certificates issued by the UECC Seminary are documents of religious authority, yet are considered incidental tokens of the UECC Seminaries appreciation of your donation level and commitment in knowledge and or faith. The certificate or document simply displays your office, as you receive the factual authority of office through placement of your information within the various registries of authority in the UECC Seminary. A theological degree of higher learning becomes legal by granting authority within the School registry. Religious authority is the placement within the Church registry

Some data and information as to the stance of St. Charles Borromeo Seminary regarding non-accreditation versus accreditation.

First, we must look at historical reality and political reality.

Legals:

The Constitution and laws of the United States dictate clearly the following:

First Amendment: An Overview

The First Amendment of the United States Constitution protects the right to freedom of religion and freedom of expression from government interference. It prohibits any laws that establish a national religion, impede the free exercise of religion, abridge the freedom of speech, infringe upon the freedom of the press, interfere with the right to peaceably assemble, or prohibit citizens from petitioning for a governmental redress of grievances. It was adopted into the Bill of Rights in 1791. The Supreme Court interprets the extent of the protection afforded to these rights. The First Amendment has been interpreted by the Court as applying to the entire federal government even though it is only expressly applicable to Congress. Furthermore, the Court has interpreted the Due Process Clause of the Fourteenth Amendment as protecting the rights in the First Amendment from interference by state governments.

Freedom of Religion

Two clauses in the First Amendment guarantee freedom of religion. The Establishment Clause prohibits the government from passing legislation to establish an official religion or preferring one religion over another. It enforces the "separation of church and state." However, some governmental activity related to religion has been declared constitutional by the Supreme Court. For example, providing bus transportation for parochial school students and the enforcement of “blue laws" is not prohibited. The Free Exercise Clause prohibits the government, in most instances, from interfering with a person's practice of their religion.

Taking this is simple context, you may extrapolate that by requiring “oversight” of religious training of clergy is an exercise that may impede the free exercise of religion.

Under the laws on the United Stated Code 26 501 (c3):

Churches (including integrated auxiliaries and conventions or associations of churches) that meet the requirements of section 501(c)(3) of the Internal Revenue Code are automatically considered tax exempt and are not required to apply for and obtain recognition of exempt status from the IRS. Donors are allowed to claim a charitable deduction for donations to a church that meets the section 501(c)(3) requirements even though the church has neither sought nor received IRS recognition that it is tax exempt. In addition, because churches and certain other religious organizations are not required to file an annual return or notice with the IRS, they are not subject to automatic revocation of exemption for failure to file.

This section of United States code clearly states that the Federal Government considers a church or subsidiaries totally exempt from all Federal requirements. If we take this in context of regional and national accreditation associations, that REPORT to the Federal Government, it may be extrapolated this oversight of a seminary may impede the free exercise of religion.

This is supported by 26 508 (c1a). With the passing of the Johnson Act in 1954, the IRS Code 508 is an extension to IRS Code 501 and specifically calls out exceptions:

(c)Exceptions

(1)Mandatory exceptions Subsections (a) and (b) (previous) shall not apply to—

(A)

churches, their integrated auxiliaries, and conventions or associations of churches, or

(B)

any organization which is not a private foundation (as defined in section 509(a)) and the gross receipts of which in each taxable year are normally not more than $5,000.

The 508 Code verifies that churches, their integrated auxiliaries, and conventions or associations of churches are exempt from Federal Government interference, and my infer that regional or national accreditation associates reporting to the Federal Government and performing oversight of a seminary may impede the free exercise of religion.

Appendix I

Issues Regarding Accreditation

Much of the following information is taken from various sources including The History of Seminary Education and Theological Accreditation and Problems Observed in Seminaries based on writings of Gregg and Krejcir.

• Mainstream accredited seminaries have been pricing themselves out of the market for decades. No small part of that issue is accreditation is not an inexpensive task. Even for small to medium scale seminaries, the initial cost of accreditation can be in the 10’s of thousands and into the 100’s of thousands of dollars in overhead investment. That does not account for ‘membership’ fees that run in the high four digits of overhead cost. There any many (far too many) incidental costs per year or per accreditation to list here.

• The cost of seminary has kept pace with secular university costs. The issue at hand here is two fold;

  • Accredited seminaries do have access to federal direct loans by virtue of accreditation. The issue is this binds the seminary to the government, which violates the churches right (and seminary) to operate without governmental oversight or intervention.

  • Along with the seminaries structured similar to a secular university, accreditation costs/overhead, and other factors it is no longer unusual for per credit costs of $650.00 or even higher to achieve a Bachelors of Theology. This does NOT include living costs. And many churches (sadly) are requiring a Masters. The underlying issue is the church monies to support scholarships is drying up at an alarming rate. Very few seminarians can afford 4-6 years of seminary and pay off the loan on the wages most clergy make in their first church assignment. Many churches facing financial issues themselves, are actually no longer paying some of their clergy, they must seek secular employment. While this is how Independent Churches Operate, the mainstream churches operate as businesses, and the situation for them is a hard pill to swallow.

• Far too many seminaries seek to conform to secular universities and focus on new and "career scholarship" to the detriment of training students correctly. Most offer little encouragement for growing in the faith, either watering down theology or making it so overly scholarly that it is un-practical, un-touchable, and un-teachable in a local church.

• Most seminary courses are seen as irrelevant to the type of ministry the students, who are in the ministry now, face. They see doctrine as dry and unfulfilling or unrelated to faith and practice when in fact, doctrine is thrilling because it means learning about our Lord and Savior!

• Many seminaries offer little encouragement for growing in the faith, either watering down theology or making it so overly scholarly that it is un-practical, un-touchable, and un-teachable in a local church.

• Ministry preparation is lacking in theological education! Graduates leave seminary with little to no application on how to lead and manage a church, council a person in distress, or relate Bible doctrine to the everyday ongoing of their own lives and congregations.

• Most seminary students are finding their theological instructions, books, and curriculum to be pragmatically vacuous and irrelevant to them and/or their congregation's life; for them, seminary is not practical.

• Many graduates of seminary think that there is a "double-consciousness" of being a theologian and a Christian disciple, that the two cannot be related. Thus, the result is being unwilling or unknowing of how to build a congregation up in love towards Christ and one another.

• The emphasis in seminaries is so scholarly now, there is disconnect between effectual faith and academic knowledge. Thus, students cannot put together faith and reason or lead themselves or others deeper in real, authentic Christian formation. They graduate without the tools to be pastors and leaders for today's churches.

• Seminaries have left behind the requirement for logical sermon preparation and especially delivery. Far too many clergy today simple cannot write an understandable sermon and have negligible speaking skills.

• There is an increasing lack of practicum in the seminaries. Most have become so institutionalized in the ‘secular’ format of book learning and rote memorization, there is little or no time to actually practice being clergy. Practicing the liturgies, offices, writing sermons, delivering sermons, interactions with the public, proper Altar Guild Techniques – all are lacking.

• Far to many of the teaching staff perform their tasks as theologians. They no longer desire to provoke free thought, demand spirituality as part of a seminaries individuality, how to pray, how to pay reverence, how look for the deeper faith. Teaching as theologians has an adverse effect; the seminarians bogged down in deep debate, rather than searching for deep faith.

• Far too many accreditation associations have members of the board of directors that are actually from the seminaries that are being accredited. Hence, a school is accrediting itself, and that becomes an issue of ethics.

• The Scholastic Focus of the Seminaries. Unfortunately, the scholastic, academic framework that God used to bring revival to the Church in the Reformation became a scholastic bottleneck that choked the life of God from seminaries and seminarians. Seminary leaders became enamored with scholarship more than practical ministry training.

• Seminaries often turn a deaf ear to the needs of the local church and arrogantly defend scholarly education

• The narrow focus on scholasticism in seminary education left no room for the Holy Spirit to move or guide the learning process.

• Whitefield characterized the schools as “not far superior to our <secular> Universities in piety.” The devolving of the seminaries was seen as far back as the mid 1700’s.

• Seminary does not facilitate spiritual growth; it frequently lacks a deep spiritual base

• There is a gap between the education provided and the pastors’ duties as performed.

• Modern training is primarily intellectual.

• Schools which are separated from the local church are very apt also to be separated from that real world where the future minister must labor.

• According to the Murdock Trust: In the pastors forums those who were seminary graduates reported that they found 70% to 80% of their seminary education did not apply to the duties they were expected to perform in the churches they served as ministers.

• Pastors are highly educated but generally feel poorly prepared for the job they hold.

• John Woodyard: Currently, major rewards for the seminary professor are research-based, academically and intellectually-based affirmations from published books and articles. Unless different spiritual, emotional, economic, and social rewards for the professor can be created, little or no change can be expected in seminary operations, relationships with the churches, or instruction for the students.

• Murdock Trust: Authority for the seminary rests in the control of accreditation associations. Evaluation is built around the shrouds of academic freedom and tenure as defined by their peers in the accreditation process.

• Seminaries are denominational based. This creates a real issue with respect to accreditation. One of the major point of the accreditation process is credit the capability of transfer. That process fails across denominational lines.

• Accreditation Associations disagree with one another on standards

• There is much discussion of the logic of seminaries on secular campuses. Secular events of dubious morality creates a haven for clergy morality shortfalls.

Appendix II

Issues regarding Operations of Accredited Seminaries

Operations of Seminaries today is based totally on University Models. This creates a myriad of issues that may not be immediately apparent. Some examples:

• The seminaries are surrounded by a purely secular environment that is not conducive to to the moral substance of any religious studies.

• One of the biggest complaints by seminarians is too much of the curriculum is rote memorization and finite question/answer testing. This does not and cannot work in a ‘denomination’ based religious environment.

• With concentration on ‘university academics’ as an outcome, hands on training on how to perform the duties of clergy is minimalist (nearing non-existent).

• Public speaking (sermons/homilies) are not a major part of accredited seminary curriculum. This is a major portion of the duties of clergy. Far too many clergy have tragic outcomes on the pulpit via this omission of training.

• Far to many Bachelors degrees contain secular ‘components’ in the curriculum. Most have no relationship to the religious environment.

Accreditation lends itself to ‘forcing’ seminaries into a University Model. Some examples of the issues:

• Increases the likelihood that far to many ‘secular’ activities and curriculum will hinder the religious aspect of the seminarians experience.

• Raises costs due to the relatively high cost of accreditation.

• Accreditation cannot take into account ‘denominational’ differences and requirements.

• Private accreditation agencies have far to many Seminary/University staff that sit on the Board of Directors of the Accreditation Agencies. Therefore, these seminaries are being accredited by their own staff.

• Accreditation stresses academics and not seeking true theology or the search for the divine, which is the basis for the existence of clergy and their practice.

Cost of seminaries is out of control and beyond the reach of seminarians.

• One of the main reasons for seminaries to accredit is to provide scholarship assistance. This is very misleading as scholarships traditionally over cover 10-19% of the overall cost.

• In many of the accredited seminaries accepted by the top four (4) mainstream churches the credit hour costs range from $400.00 to $700.00 for the two main degree programs – Bachelors and Masters

• A bachelors degree is normally 120 credit hours and takes 3.5 to 4 years to complete. The tuition alone may approach or exceed $84,000.

• The average book costs nationwide can exceed $3000.00

• Incidental charges can approach $2000.00

• If the seminarian MUST live on campus, the cost per year for lodging ranges from $14,000 to $20,000 per year. That equates to $56,000 to $80,000 for housing. If they have a family and wish to live off campus, that costs rises substantially.

• Masters degree with a nominal 60 credits comes in at approximately $42,000 or more. This excluded book costs and incidental costs.

• If the seminarian for the masters must live on campus as describes above, a typical masters is two (2) years and that adds $28,000 to $40,000 in housing costs

• Most mainstream churches require a masters. If we assume a seminarian can complete both degrees in 5.5 years, the total costs floats around $200,000.

• If we assume that the seminarian obtains the ‘normal’ scholarship assistance (we will use 19%)⁵ the seminarian must pony up $162,000. Only 7% of all scholarships are awarded across all universities and seminaries in response to student aid requests.

• Assuming the seminarian obtains a 3.8% student loan with a term of 20 years, the monthly payment alone is $1500 per month.

• The median wage of a starting clergy sits roughly in the range of $35,000 to $50,000 per year. Keep in mind many small churches can no longer afford ‘free housing’, and even if the clergy obtains free housing, the payments on the student loan brings them down to near the poverty level.

• We must keep in mind the seminaries that have endowments provide ‘minimal’ financial assistance. The total endowments in the United States sits at approximately $30 Billion. The seminaries use the interest money made on the endowment to provide financial assistance, and is in the mere millions. This covers only a small percentage of seminarians. The rest of the endowment goes for wages, operations and property.

Time is one of the critical issues related to bringing clergy into the church.

• Normal seminary to obtain the masters requirements of our mainstream churches is optimally 5.5 year (sometimes more). Most seminarians do not have active employment, or a simple low wage part time employee, during this period.

• Many mainstream churches require a ‘minimum’ formation period as a deacon of one (1) year (sometimes more).

• Some mainstream churches require a further formation period beyond these requirements and varies widely (2-4 years).

• Deacons are usually unpaid

• Total time without meaningful employment can be 6-8 years or more.

Monastic or non-Accredited Seminary Training

For 1800+ years of church history, ‘university’ training of clergy was reserved only in special cases of clergy who desired to ‘debate or research’ topics with theology or divinity.

Clergy who desired to ‘practice’ as priests were trained in a more monastic environment. These clergy were trained not only in theology and divinity, morals and ethics, but they had to ‘practice’ all of the hands on required in the daily duties of a priest.

The example that brings this into context was the Roman Catholic clergy member by the name of Martin Luther. Luther was trained in monastery, NOT university, predominately by von Staupitz. He was ordained a priest and was ‘practicing’ a full calendar year before von Staupitz suggested Luther enter university training so that he could ‘debate and research’.

Future of the Seminary in the Christian Religion

The day is long past that seminary training would benefit from being removed from the university environment, and held aloof of the restrictions, costs and secular issues presented by accreditation.

 Non-Accredited Seminaries and Monastic training produces working clergy. Accredited Seminaries produce theologians, debaters, researchers and scholars.

The world today needs clergy, those individuals who bring the word the people and are trained to be shepherds.