Fickle Government, an Unchanging Church, and the Support of our Pastors

augustus-prima-porta-2Today there is news of a new decision in a federal district court which takes away some exemptions that have in the past helped pastors.  This could have some very hard consequences for men serving in already difficult situations.  There is a chance that this ruling could be overturned (by another court) or that Congress could change the law again (it did that when this came up a while ago to meet IRS language requirements).

Here is my summary of the stuff going on:  the new ruling removes the ability for pastors in this federal district to deduct from their taxes housing allowances and similar things.  These things were given to pastors because of their very strange tax status (half employee, half self-employed).  Being not fully employee, they cannot do some of the things that normal employees can (they have to pay the “employer” match for Social Security).  Being not fully self-employed, they cannot deduct as much as self-employed folks can.  The housing allowance exemptions were meant to offset this.  The same exemptions are granted to military personnel.

I think the hidden scandal here is that our pastors have been having to rely upon government benevolence in order to live out their daily lives.  I know of pastors who have had to take food stamps, WIC, Medicaid, and various other benefits (including Federal Student Loans and their repayment plans).  The scandal here is not that pastors are using these things to support themselves and their families, but the scandal is that the Church as a whole has not seen this as a problem and addressed it.  I know putting food on pastors tables and helping them to pay the light bill does not make for great color glossy ads promoting the church, but we can do better.

As we see the role of government changing in our times, it is very likely that many of the previous favors given to the Church by the State are going away.  This should not be a surprise to any student of Lutheran history as Lutherans in particular understand the fickle nature of government, divinely ordained and yet filled with sinners.  We should understand that at times the government can be a great blessing to the Church (Frederick the Wise, John the Steadfast….) but also that it can be very much an opponent to the Church (Frederick William III and the Prussian Union as only one example).  The last example, that of government opposition to the Church was very formative in the Lutheran Church – Missouri Synod, as seeking religious freedom from their fatherland they set up a Church that did not rely upon the government at all.  CFW Walther even rejoiced in the freedom of the Church in this land.  The early years of the LCMS in this nation could be considered almost “sectarian” as we kept to ourselves and did things ourselves (for instance our insistence on parochial schools for every congregation at the beginning).  As times changed however, even the LCMS warmed to the favors granted to it and its members by the government.

The decisions in regards to the contraceptive mandate, student loans, health insurance, and now these exemptions remind us that governments can change in their relation to the Church.  What can an honest Lutheran do?

First, pray.  Pray for those in authority over you.  Pray that they would be God’s agents to punish evil and reward good.  Pray for those effected by all of these decisions.  Pray for the pastors.  Pray for the teachers.  Pray for the congregations.

Second, be a citizen.  God has made you a ruler in this land by right of your citizenship.  Our republican form of government allows for you to vote on candidates to represent you and also to call upon those elected representatives with your concerns.  For more on this, consult the Augsburg Confession, Article XVI.  Perhaps God will through government show that kind of favor to His Church again.

Third, be honest with ourselves.  We have sometimes become too reliant on government for its favor.  Instead, we should return to what we believe, teach, and confess as a Church about how we take care of those who minister among us.  We should once again look to the Augsburg Confession (articles V, VII, VIII, XIV for starters) to see what it is the Church is to be about (Word and Sacrament) and how God brings that about (through the ministry of teaching the Gospel and administering the Sacraments).  A good reread of the Table of Duties of the Small Catechism would be a great idea as well.  Not only a return to the simplicity of being the Church of Word and Sacrament, but also some new ideas need to be brought to the table on how to help each other in this “Life Together” to support congregations and pastors.   We need to begin, as a Church body to think of and prepare for the worst case scenario, a government that is not only not showing favor, but one which is hostile to the Church.  This means teaching the faith to all ages.   This means setting up support mechanisms outside of any form of reliance on government.

How does this look in the LCMS?  I don’t know.  We have a lot of resources that we could bring to bear on the situation if we could focus on it.  We have some excellent leaders who are well versed in theology, church history, and have good gifts for the time at hand.  Pray for them as they seek to lead the Synod through this messy world and its fickle changes.

From the Table of Duties, What the Hearers Owe Their Pastors:

The Lord has commanded that those who preach the gospel should receive their living from the gospel. 1 Cor. 9:14

Anyone who receives instruction in the word must share all good things with his instructor. Do not be deceived: God cannot be mocked. A man reaps what he sows. Gal. 6:6–7

The elders who direct the affairs of the church well are worthy of double honor, especially those whose work is preaching and teaching. For the Scripture says, “Do not muzzle the ox while it is treading out the grain,” and “The worker deserves his wages.” 1 Tim. 5:17–18

We ask you, brothers, to respect those who work hard among you, who are over you in the Lord and who admonish you. Hold them in the highest regard in love because of their work. Live in peace with each other. 1 Thess. 5:12–13

Obey your leaders and submit to their authority. They keep watch over you as men who must give an account. Obey them so that their work will be a joy, not a burden, for that would be of no advantage to you. Heb. 13:17


About Pastor Joshua Scheer

Pastor Joshua Scheer is the Senior Pastor of Our Savior Lutheran Church in Cheyenne, Wyoming. He is also the Editor-in-chief of Brothers of John the Steadfast. He oversees all of the work done by Steadfast Lutherans. He is a regular host of Concord Matters on KFUO. Pastor Scheer and his lovely wife Holly (who writes and manages the Katie Luther Sisters) have four children and enjoy living in Wyoming.


Fickle Government, an Unchanging Church, and the Support of our Pastors — 31 Comments

  1. Excellent treatment, Pastor Scheer. This is not a problem we have with the state. This is a problem we have within our synod of churches. Thank you for taking us to the Small Catechism Table of Duties.

    Whatever Caesar giveth, Caesar taketh away eventually.

  2. Pastor Scheer,
    Good post. I would add to your second response on what to do as a citizen– run for public office. We need to fill the government with those well versed in understanding two kingdom theology.
    Pastor Theodore Cook
    Pittsburg, KS

  3. Nicely put.

    I am one of those LCMS pastors who had to rely on WIC to feed my family, and I remember a shrewd business man years ago who had calculated roughly what my tax return would be and included that in my salary for the upcoming year.

    I know that many congregations cherish their pastors – and even within a congregation there will be those who do a good job supporting the livelihood of the one who administers the Word and Sacraments in their midst and those who do not. It is not, however, the government’s job to provide the means to support our life and ministry. I am thankful for the benefit I have received from the US government that has helped me feed and raise my children, but it is better when the servants of the LORD do not need financial help from the state.

    And if the financial assistance of the government is removed, what then? We keep sharing the Gospel. This may turn in to a great moment of repentance for the church and a time of deeper faith as we learn to rely more on the LORD than on the world.

  4. As Christians, we should not be surprised if more changes to the tax system aimed at increasing govt. revenues. The nations economy is pretty sick, contrary to what the news media feeds us. Govt. will continue to look for sources of revenue to fuel its control and gifts to its friends. Someday, our property tax and charitable gifts tax breaks will also likely disappear.

  5. The daily lectionary reading for the 23rd from the Old Testament was in Daniel and Shadrach, Meshack, and Abendego were thrown into the furnace. I’m not saying that this is happening to Christians in the US or that this is like that, but it is just a reminder of our calling to follow God, no matter what special benefits the government does or doesn’t give or take away.

  6. Dear BJS Bloggers,

    I can see two sides of this issue.

    From the government’s side, all that they CAN see is the salary and benefits of mega-church pastors. Some of these were investigated by the Senate Committee led by Senator Grassley. Joyce Meyer in Saint Louis cooperated with that investigation, most of the other pastors did not.

    The problem is that these mega-church pastors live in mansions–with “help”–and everything else you can imagine, and it is all sheltered from taxes as “housing allowance.” These mega-church pastors are better off than our Congressmen and some of our Senators—and that is sure to draw attention! 🙂 I think that there should be some kind of cap on the housing allowance for those ministers who make these type of salaries.

    The government has the problem that it has to construct a law that applies to all denominations, religious faiths, and church polities. That is not an easy fix–more like a legislator’s nightmare!

    For those of you who don’t understand it, the housing allowance works like this. If you are allowed to shelter part of your income from taxes, then you will take the most advantage of that shelter that you can. This is a primary principle of any sound financial planning with tax-consequences in mind. So whether the pastor owns his own home, rents or leases, or lives in a parsonage arrangement, the more he spends annually on IRS-qualifying housing expenses, the less he pays in taxes. That just makes sense.

    The housing allowance was designed to offset the Social Security and Medicare “penalty” that all ministers of religion pay to the government. That part is true, and it is fair and reasonable for 99% of all church-workers. Most church-workers, in all denominations, have salaries and benefits that are too embarrasingly humble to talk about. Denominations want to stretch the “mission money” as far as it will go; and I can agree with that.

    But we can’t let any of our church-worker families fall through the cracks. Adding exorbitant student loans on the top of meager entry-level salaries for church-workers is insane–simply financial insanity and irresponsibility–not on the part of the church-workers who receive, but those who give it.

    Taking away the housing allowance, if that is what this results in, will really hurt all of the youngest workers who have entry-level salaries as well as any-age church-workers in the small “inner city” and rural churches. And they have already been hurt by this recession.

    I don’t know the specifics on this court decision, so I can’t give any specific suggestions at this point, but if it moves farther along, it would make sense for the Congressmen you know to write up a bill so that the average church-worker, and especially the young and penurious ones, are not financially bled-out of the ministry. I think that most of Congress–both houses–would agree to that.

    Yours in Christ, Martin R. Noland

  7. Dear Pastor Zell,

    Thanks for the link. That is very helpful to see that the entire housing allowance is being challenged, not just one portion or aspect of it. All of our rostered church-workers should read that link and pass it on.

    The truth here is that all church-workers are really going to be hurt, just because of a few mega-church pastors who receive obscene compensation (“obscene” in light of the fact that the ministry is an office of service). I think Congress, or higher-ups in the federal government will understand that. We’ll see . . .

    Yours in Christ, Martin R. Noland

  8. Makes me wonder if the Synod couldn’t come up with a better solution, partnered with the seminaries, to provide pastors to the congregations, large or small.

    What if the congregations paid their “taxes” to Synod (rather than the districts) and the Synod made their first budget priorities funding the Seminaries (free to admitted students) and base salaries with benefits for all pastors (which could be supplemented at the congregational level, if so desired)?

    Gone would be starving pastors… unassailable student loan debt… relative gluts or famines of pastors to serve any size congregation… and our “mission” dollars would first be spent, taking care of Word and Sacrament in our own back yard.

    Just thinking out loud…

  9. About 20-25 years ago the IRS tried to get its tentacles into the pockets of the church by taking away a pastor’s “housing allowance” (a most contemptible euphemism for their thievery). It was a Baptist congressman from one of the southern states (where else?) who pointed out that members of the military enjoyed the same tax freedom, and that if they wanted to wrest it away from the clergy they would also have to take on the military. Needless to say, the effort was abandoned.

    At that time, only raw greed and lust for power could be held up as justification for intruding into the lives and bank accounts of the most decent and law abiding section of our society, poor as it was (rich T-Vangelicals notwithstanding). But it was a small group and easily brought under control. When they saw the military, an armed forces too strong to attack, allied with the clergy they had to retreat. What to do? Of course! Run to the constitution, the final word for progs who cannot get what they want through civil discourse and sound reason. If they can “prove” that the “housing allowance” is “unconstitutional” because of an “an endorsement of religion” then “democracy” will be served and “equality” established once again. Certainly only a heartless, unpatriotic, tax-evading capitalist would disagree. With the sad state of religious, “gender,” and ethical confusion plaguing our military, I doubt whether even they will be any defense for us in this battle for liberty.

  10. @Eric Tritten #3
    “I am one of those LCMS pastors who had to rely on WIC to feed my family, and I remember a shrewd business man years ago who had calculated roughly what my tax return would be and included that in my salary for the upcoming year. ”

    You mean a shrewd thief stole from you and billed us taxpayers to do it. How wicked we laymen are to withhold our wealth from the “beautiful feet of those who bring good news.”

    In my opinion, us laymen should think about our own household budgets and compare this with how our pastor is compensated. Do we spend frivolously? Is the pastor on WIC while we buy fine cigars and liquor? Is the pastor in need of state assistance while we maintain a membership at the local country club (and it’s not needed for business purposes)? Do we drive the latest in luxury vehicles while the pastor cannot provide a retirement for his wife should she become a widow?

    After we get him off state assistance we then should ask, is the pastor fairly compensated compared to *somewhat* equivalent professions in the area and according to the ability of the congregation to do so?

  11. Just received from Witmer-Wood Tax Consultants:
    As you may already be aware, the Freedom From Religion Foundation has won a stunning victory in the United states District Court for the Western District of Wisconsin where Judge Barbara Crabb has ruled that a substantial tax benefit enjoyed by many thousands of clergy – ministers, priests, rabbis, imams and others – is unconstitutional.
    In response to this, GuideStone has released the following statement:
    GuideStone has been monitoring this action in the federal district court of Wisconsin. The ruling by the judge in the case, an appointee of President Carter, is not unanticipated. For quite some time, GuideStone has been planning to join others in filing a brief with the court in support of minister’s housing allowance when the case goes up on appeal to the federal circuit court. GuideStone will use that avenue and others to speak out regarding the vital and historic role of minister’s housing allowance.
    This decision is limited to the Western Federal District Court of Wisconsin (covering much of the western half of Wisconsin). The ruling has been “stayed” (does not go into effect) until any appeals are concluded. OS Hawkins, President and CEO of GuideStone commented that “although this particular case does not have immediate impact, we know that pastors and others in ministry are facing challenges in our very own nation as never before. This decision, while not unanticipated, is sadly symptomatic of our culture today. We count it a privilege to be an advocate for those who have given their lives to ministry – and we will not forsake our mission to undergird those who so faithfully serve our churches and ministries by fighting to protect and preserve minister’s housing allowance.”

    Please know that Witmer Wood Tax Consultants is closely watching the situation. In the meantime, there are things that you can do to help fight this ruling:
    • Contact your local representatives
    • Contact your Denomination and see what, if anything, they are doing to protect your Housing Allowance
    • Pray

  12. This is troubling news, but news we all knew would occur sooner or later, just seems things are getting ramped up a bit faster of late.

    And yes, this will highlight the fact that there are some pastors out there getting hurt by Churches that are not paying them a living wage (or cannot even if they wanted).

    It certainly seems a few answers are:
    01) Revenue sharing like baseball, etc.
    02) Go to a more ecclesiastic model.
    03) Union like pay scale, enforced by Synod.

    Of course, these can never happen in our polity.

    One thing this will do, force all of us to access the cost of men in the pastoral office at a more hurried pace.

  13. I do believe the other reason this is occurring now is the fact that housing allowance does not count as income when calculating Obamacare (I mean the Affordable Care Act) stipends to offset health care through the Exchange.

  14. @Brad #10
    What if the congregations paid their “taxes” to Synod (rather than the districts) and the Synod made their first budget priorities funding the Seminaries (free to admitted students) and base salaries with benefits for all pastors (which could be supplemented at the congregational level, if so desired)?

    You mean, support Synod like the congregations did, before “districts”?
    What an interesting idea!

    I don’t know about the salary part, [absolute power corrupts absolutely] but getting seminary costs out of the stratosphere would solve many other problems!

  15. @helen #17

    I agree that a huge part of this equation, is getting Seminary costs under control. Perhaps part of that, would be getting the Seminaries out of the business model of trying to sell programs and recruit new candidates… and simply have them funded as the primary mission expenditure of the Synod. We evaluate young men and women for their potential of service within our Synod, and then send them– fully subsidized– to receive the education they will need to serve the Church.

    I’d be willing to bet we have plenty of funds at the Synodical and District levels to do this– the bigger question is whether or not the people of our Synod value our pastors and church workers enough to invest in them. Where our treasure is, there is our heart…

  16. @helen #17
    Nope…this would not work, unless you want to go to a more Ecclesiastical model. And this would then work, BUT you would get the other side of the equation. Synod has control, to place, to fire, to close, to…..just like the Roman Church.

    Then again Helen, you are on to something…

  17. If you want to know _why_ the housing allowance exemption is being challenged, you should read the FFRF’s explanation since they are the ones challenging it. It has little to do with Rick Warren or Osteen or the like. It has everything to do with militant atheism. For them this is just the tip of the iceberg. They expect that by attacking this “small” (not small to my family) portion of the tax code they can get every exemption from taxes taken away from churches. If this ruling holds as stated, then there is no logical reason for the govt. to be allowed to give _any_ support (by way of tax breaks) to religious organizations. It will take a while because the FFRF and others won’t want to break the non-profit tax exemptions that benefit planned parenthood, etc. but they will work hard on it.

    Ironically, the constitutions protection of churches against the intrusion of the state is being twisted into the opposite. To wit, the state will eventually try to control the church through taxation just like it controls local school districts, police and fire depts. and even transportation.

  18. @george #20
    The dollar amounts mentioned in the link in postin # 8 do indeed seem to indicate that the intent of the lawsuit and the ruling is to hurt pastors such as ours, with salaries roughly in the ball park of the guidelines I know from such Districts as South Dakota and Wyoming, rather than mega-church and media millionaires.

  19. @Pastor David L. Prentice Jr. #19

    Pr. Prentice,

    I’m not sure I understand what you mean by a “more ecclesiastical model,” though I think you might mean a more episcopal model, with more authority vested in the bishops and their political structure. While I don’t think that would be an entirely bad thing (and something our Confessions seem to assume, anyway,) I agree it would be contrary to our LCMS construct.

    However, I don’t think we’d have to do that, to fully fund our seminaries, and subsidize our seminarians. We already have admissions and colloquy boards– all they really need is the money. And if our domestic mission money was primarily directed at the seminaries and their students, I think it would encourage a “right sizing” of the number of clergy in the Synod, and reduce the financial burden on those we encourage into the Lord’s Office of the Keys. Without making a value statement on the relative value of different ecclesiologies, I think we could do this one without any significant changes to our structure… we’d just have to change how we spend our money.

  20. Districts were formed as appendages of Synod. However, under the present set up congregations send a portion of their funds to the district. Each district then remits a portion of funds received from the congregations to Synod. Thus the power of the purse sits with the districts. It’s a bit like the tail wagging the canine. It seems that Helen’s position has merit, but it is not at once evident how such an arrangement would tend toward an Ecclesiastical system. We already have an Ecclesiastical system with District Presidents of the several districts.

  21. @Pastor David L. Prentice Jr. #19
    Synod has control, to place, to fire, to close, to…..just like the Roman Church.

    Like some LCMess DP’s… ?

    @LaMarr Blecker #24
    We already have an Ecclesiastical system with District Presidents of the several districts.

    What we already have is 30+ little popes, controlling the money and therefore the headquarters.
    I find it hard to believe that was ever meant to be.

  22. helen :
    @LaMarr Blecker #24
    We already have an Ecclesiastical system with District Presidents of the several districts.
    What we already have is 30+ little popes, controlling the money and therefore the headquarters.
    I find it hard to believe that was ever meant to be.

    Someone has to “place” pastors into churches. Oops, sorry, help congregations through the call process. My bad.

  23. … and I know and understand that it can be hard for some of you to believe, but we do also have some District Presidents who are not really all that popish, but actually are brothers, supportive of faithful Lutheran Pastors, and faithful Lutheran Pastors themselves, with an intention to serve and assist rather than reign …

  24. Dear BJS Bloggers,

    I second what Jais Tinglund has said in #27 above. We have always had faithful, orthodox, dedicated, charitable, and fair-minded presidents in our LCMS districts. Just not in all of them more recently in our history.

    Folks who don’t know LCMS history don’t realize that the movement to investigate the seminary in Saint Louis in the 1960s was really spear-headed by the LCMS district presidents. It was known as “Faith Forward First Concerns.” About a dozen DPs, that would be one third, signed on to a petition to the president of the synod to do his duty in this matter. About another third agreed, but considered it wise not to sign the document. About another third were probably sympathetic to Saint Louis and the later Seminexers. Eight of them later ordained Seminex graduates.

    Our last series of district conventions in 2012 moved many of our districts in a more traditional direction by election of new district presidents, replacing those who have retired. As I have said many times, it is a “passing of the torch to the next generation” type of thing.

    I do have sympathy for pastors and congregations in districts where there is less support for being faithful to our distinctly Lutheran theology and practice. No names will be named here by me, and preferably not by others in the following comments. I have lived on both coasts, and I have Lutheran relatives in other states, so I know whereof I speak . . .

    On the matter of the clergy/teacher/deaconess/DCE/etc. housing allowance, I would be surprised to find ANY district president in favor of eliminating that tax allowance–after all, he would be affected too . . . 🙂


    Back to the topic of the allowance: if the argument by the proponents for its elimination is the “separation of church and state,” then it should be also argued that no civil government should tax any employee of the church for anything, since the ministers are obviously part of the church. Ministers of religion, by that argument, should not have to pay any income taxes, property taxes, or anything else of that sort. Then ministers of religion should not have to pay for, or be qualified for benefits under, Social Security, Medicare, etc. This would be a true and absolute separation of church and state in the matter of taxation–but I am not personally in favor of that. I am always willing to pay my fair share of taxes (Romans 13:6-7).

    The housing allowance was originally called a parsonage allowance. Why parsonages? In the rural setting, where else is a pastor and his family going to live when all his members live on family farms? In the urban setting, where else is a pastor going to live when no property is for sale at an affordable price, only for rent or lease, and that often at exorbitant rates? Parsonages still make a whole lot of sense for rural or urban congregations or very-high-cost suburban areas.

    The parsonage was originally a benefit, not considered income, for the pastor. He had that benefit only as long as he worked at the church. The parsonage only came into the tax code when Social Security came along and the federal government decided to tax the annual value of the parsonage–or the value of a rental home–or the actual cost of an owned home. At least that is how I understand it came into the tax code. A historian of American taxes, or a tax expert, could say for sure on that point.

    Even today, parsonages still make sense, even in suburban areas or towns where housing is affordable. Pastors are often required to move around the country, just like military personnel. If a parsonage is not offered to a pastor, he might rent or lease, but then builds no equity for retirement. If he decides to buy, he needs on the average five years to recoup the costs of purchase alone–before he starts really building equity. If he has to move every five years, then he never builds any equity for retirement. An every-five-year move means that in retirement, he has no equity to buy a house. He is forced, then, like some pastors I knew of my grandparents’ generation, to live in a trailer court home, or a dilapidated cottage in the worst part of town, the rest of his days–or beg for help from his own family.

    Only career military families understand the situation that faces pastors in America in the matter of required constant moves, as others have noted on this blog.

    I see that Norm Fisher has just posted a “Great Stuff” with an official statement from Ron Schulz, LCMS national office CAO. Conversation on this topic can continue there . . .

    Yours in Christ, Martin R. Noland

  25. @Martin R. Noland #28
    If a parsonage is not offered to a pastor, he might rent or lease, but then builds no equity for retirement.

    I find this argument a little odd, for two or three reasons. First, we are no longer a nation of farmers, with a “big house” for the growing family and “Granny quarters” somewhere on the place for the old couple (or more likely, the widow). Most of us have been transferred, willingly or unwillingly, some of us more often than many Pastors’ families.
    [My oldest son picked his college because he could go there four years. He’d never been in one school that long.]

    Perhaps because of that shifting around, I didn’t see that house ownership added that much more to retirement. [In fact, I’m still working.] There were certainly advantages in comfort over a small apartment… (and in ‘respectability’ since many of those who own property look down on apartment dwellers).

    Finally, occupying a parsonage is no security for a widow. I knew one who was asked to leave in less than a month after her husband died. Fortunately the district intervened and she was given more time to settle her affairs and figure out what she was going to do next.

    The military goes where it’s told but often has the option of base housing (“an apt”). Pastors, unless removed unlawfully, leave when the next call seems the better thing to do, not quite the same. By your description of “required constant moves” one would think we operated on the Methodist system.

  26. @helen #29
    Wow, I would disagree, home ownership for most middle and above income people is key as we retire. Perhaps the housing bubble bursting has incurred some problems, we will hang on to the house longer, but equity in a house is key. OK, many have borrowed against the equity.

    I do think building up equity, or lack of for many pastors is a problem.

  27. @Pastor David L. Prentice Jr. #30
    I do think building up equity, or lack of for many pastors is a problem.

    It may well be. My point is that they (and the military) are not the only ones who have a hard time “building up equity” because moves or dismissals do not necessarily coincide with an “up” market.

    Many congregations expect their Pastor(s) to present the appearance of living as well as the upper half of them, while paying an average of the congregation. Or less. And then the Pastors should set an example by giving 10% back. Perhaps the Pastors should give 10%, but directly to our seminaries or reputable charitable RSOs, so the finance officer isn’t calculating it in the local budget.

Leave a Reply

Your email address will not be published. Required fields are marked *

Notify me of followup comments via e-mail. You can also subscribe without commenting.

This site uses Akismet to reduce spam. Learn how your comment data is processed.