The Ministerial Obligation is provided in the PCA Handbook for Presbytery Clerks, year after year. All teaching elders must sign the same Confessional Subscription (BCO 13-7) corresponding to the same ordination vows (BCO 21-5) in order to be ordained, and their presbyteries must retain these contracts on file.


Editor’s note: This treatise first was published as “An interaction with L. Roy Taylor’s ‘The Validity of a Call’ (in respect to the PCA’s uses of its out-of-bounds provision with non-PCA churches and the PCA Confessional Subscription/Ordination Requirements for Ministers),” on September 18, 2020, as Appendix V in the Complaint of Peter Benyola versus the Central Florida Presbytery, elevated on December 7, 2020, to the General Assembly of the Presbyterian Church in America, becoming SJC (Standing Judicial Commission) Case No. 2020-13. The only change is retitle. 

Our denomination’s esteemed third Stated Clerk of the General Assembly, L. Roy Taylor, produced observations in 2004 after his committee was asked by North Georgia Presbytery to study the matter of the validity of a call for ordination candidates and for ministers seeking to transfer into the Presbytery. Dr. Taylor’s research provides some informative history and thoughtful reflections of how the Presbyterian Church in America judicatories have used The Book of Church Order 8-7. 

This Church member hopes to constructively contribute to the discourse by showing that while courts may, at their “discretion,” authorize out-of-bounds calls, the Confessional Subscription that binds all our Presbyterian ministers is quintessential to and inextricable from such discretion. Far from being a mere intramural debate, the enforcement of subscription helps us to guard and maintain the integrity of our doctrinal standards as a Reformed and Presbyterian Church before the Lord whose precepts our Book of Church Order acknowledges are jure divino: “by divine law.” 

Part I: Form of Government
Chapter 8: The Elder
8-7. A Presbytery may, at its discretion, approve the call of a teaching elder to work with an organization outside the jurisdiction of the Presbyterian Church in America, provided that he be engaged in preaching and teaching the Word, that the Presbytery be assured he will have full freedom to maintain and teach the doctrine of our Church, and that he report at least annually on his work. As far as possible, such a teaching elder shall be a member of the Presbytery within whose bounds he labors. (See BCO 20-1.) 

As the out-of-bounds clause has been employed by presbyteries to cooperate with various types of organizations over the half-century of the PCA’s existence, it is due and substantial to consider that questions and answers which bear upon how presbyteries may properly and lawfully grant permission for its teaching elders to labor out of bounds necessarily have implications for how the entire denomination may interpret and use BCO 8-7. This response will interact specifically with Dr. Taylor’s comments on how ministers are allowed to labor at non-PCA churches, especially given this Church member’s direct experience with clerical loans of Central Florida Presbytery. 

As perspicuous as The Book of Church Order is in most places, there can be interpretive challenges in understanding what Church order intends with certain terms that have been used to refer to settings outside the purview of the BCO: such as “definite ecclesiastical call,” and if such terms are meant strictly within the BCO’s framework as they apply to only PCA churches, or if they pertain also to churches that are outside PCA jurisdiction. We are all learning. Dr. Taylor helpfully wrote, 

“The BCO is written to give, first of all, general principles of biblical polity (BCO 21-5, 24-5, Q. 3). In some instances there are detailed procedures to follow, but the intent is that lower courts use their discretion (BCO 11-3, 11-4). It seems to me therefore, that it would be unwise for the committee to propose a list of acceptable or unacceptable calls. Rather, I think the committee should draw together the relevant applicable principles of polity and that each case that may arise be considered on its own merits in light together the relevant applicable principles of polity.” 

It is the “relevant applicable principles of polity” that we are most concerned with in this dialogue, particularly as it pertains to the PCA Confessional Subscription, and how our presbyteries may be constrained from permitting officers to labor in environments that routinely present inherent conflicts of interest with the standards our ministers avow to maintain, teach and practice in that Confessional Subscription in order to be PCA-licensed and PCA-ordained. Since “A Presbytery may, at its discretion, approve the call of a teaching elder to work with an organization outside the jurisdiction of the Presbyterian Church in America,” then any presbytery’s “indiscretion” would be demonstrated by aspects of his proposed non-PCA call that preclude such a teaching elder and his presbytery from being “provided that he be engaged in preaching and teaching the Word, that the Presbytery be assured he will have full freedom to maintain and teach the doctrine of our Church.” 

From the standpoint of legal language, the antithesis of discretion is indiscretion. Thus, to show how a presbytery’s approval of such a call actually is “indiscreet” vis-à-vis our primary, secondary or tertiary standards entails evidence of an unsustainable conflict of interest between the TE’s Confessional Subscription and his discharge of duties in an alien call to an organization that does not uphold the PCA’s precepts which Presbyterian ordination vows bind all pastors to uphold. 

According to the PCA Confessional Subscription/Ordination Requirements and Procedures, in order to be ordained, every teaching elder must answer several questions in the affirmative. 

Chapter 13: The Presbytery
13-7. The Presbytery shall cause to be transcribed, in some convenient part of the book of records, the obligations required of ministers at their ordination, which shall be subscribed by all admitted to membership, in the following form:
I, _______________, do sincerely receive and subscribe to the above obligation as a just and true exhibition of my faith and principles, and do resolve and promise to exercise my ministry in conformity thereunto.
Chapter 21: The Ordination and Installation of Ministers
21-5. … Questions for Ordination. …
2. Do you sincerely receive and adopt the Confession of Faith and the Catechisms of this Church, as containing the system of doctrine taught in the Holy Scriptures;
and do you further promise that if at any time you find yourself out of accord with any of the fundamentals of this system of doctrine, you will on your own initiative, make known to your Presbytery the change which has taken place in your views since the assumption of this ordination vow?
3. Do you approve of the form of government and discipline of the Presbyterian Church in America, in conformity with the general principles of Biblical polity?
4. Do you promise subjection to your brethren in the Lord? 

The Westminster Confession of Faith
Chapter XXII. Of Lawful Oaths and Vows
1. A lawful oath is a part of religious worship, wherein, upon just occasion, the person swearing solemnly calleth God to witness what he asserteth, or promiseth, and to judge him according to the truth or falsehood of what he sweareth.
2. The name of God only is that by which men ought to swear, and therein it is to be used with all holy fear and reverence. Therefore, to swear vainly, or rashly, by that glorious and dreadful Name; or, to swear at all by any other thing, is sinful, and to be abhorred. Yet, as in matters of weight and moment, an oath is warranted by the Word of God, under the new testament as well as under the old; so a lawful oath, being imposed by lawful authority, in such matters, ought to be taken.
3. Whosoever taketh an oath ought duly to consider the weightiness of so solemn an act, and therein to avouch nothing but what he is fully persuaded is the truth: neither may any man bind himself by oath to anything but what is good and just, and what he believeth so to be, and what he is able and resolved to perform.
4. An oath is to be taken in the plain and common sense of the words, without equivocation, or mental reservation. It cannot oblige to sin; but in anything not sinful, being taken, it binds to performance, although to a man’s own hurt. Nor is it to be violated, although made to heretics, or infidels. 

The PCA has a 1976 judicial precedent, which entails considerations of subscription, that seems to have somehow eluded any mention in Dr. Taylor’s 2004 responses to the inquiring Presbytery.

A recommendation adopted following a judgment of the PCA General Assembly is catalogued in the published commentary on the BCO by Morton H. Smith, the first Stated Clerk of the PCA. 

Commentary on The Book of Church Order of the Presbyterian Church in America
Comment on BCO 8-7, p. 72
“Excerpt from Judicial Case 2, Complaint of Trinity Church, Slidell, LA, vs. Grace Presbytery, 1976, p. 50, 4-12, Digest, I, p. 299.
We recommend, apart from this judgment, that the General Assembly concur in the opinion that the Book of Church Order does not envisage the ordination of a candidate expressly to pastoral services in a church of another denomination.” 

Later documentation recounts that the same year, the PCA General Assembly overwhelmingly concurred with that Presbytery’s interpretation of BCO 8-7 regarding the out-of-bounds clause. 

Minutes of the Fourth General Assembly of the Presbyterian Church in America
September 13-17, 1976, Greenville, South Carolina
4-65 Complaint of the Trinity Church versus Grace Presbytery
“While it is not a part of the record of the case, the issue precipitating this complaint clearly relates to the ordination of a candidate for service to a congregation of another denomination.
We recommend, apart from this judgment, that the General Assembly concur in the opinion that the Book of Church Order does not envisage the ordination of a candidate expressly to pastoral services in a church of another denomination. …
The Assembly divided the report. It approved and accepted the judgment of the Commission as its action and judgment in the case. It then adopted the recommendation by a vote of 238 for and 131 against. See 4-72 for reconsideration, no change made in action.” 

Discipline is integral to a bottom-up and top-down Presbyterian polity that includes the right to an appeals process. In any PCA church, any member who is disciplined has the right to appeal, on certain grounds, the Session’s rulings to the next highest court, the Presbytery, which is the court of membership for the teaching elders who vote in discipline cases (BCO 13-9, 39-1, 42-1). 

Part II: The Rules of Discipline
Chapter 27: Discipline – Its Nature, Subjects and Ends
27-4. The power which Christ has given the Church is for building up, and not for destruction. It is to be exercised as under a dispensation of mercy and not of wrath. As in the preaching of the Word the wicked are doctrinally separated from the good, so by discipline the Church authoritatively separates between the holy and the profane. In this it acts the part of a tender mother, correcting her children for their good, that every one of them may be presented faultless in the day of the Lord Jesus. Discipline is systematic training under the authority of God’s Scripture. No communing or non-communing member of the Church should be allowed to stray from the Scripture’s discipline. Therefore, teaching elders must:
a. instruct the officers in discipline,
b. instruct the congregation in discipline,
c. jointly practice it in the context of the congregation and church courts. 

One PCA officer who enjoyed an out-of-bounds call at a non-PCA church for twenty years wrote, 

“The Westminster Confession affirms that when decisions are made at the local church level with respect to doctrine, behavior, or matters of discipline, there is a court of appeal. If a person is convicted of something in the civil realm, he has the right to appeal to a higher court. Similarly, decisions made in a local congregation can be appealed to a higher court (the presbytery), and then to the highest court (the general assembly). People who are directly involved in a dispute often become so subjective that it helps to have a higher court rule on it.”
(Truths We Confess: A Systematic Exposition of the Westminster Confession of Faith, R.C. Sproul, p. 638) 

In an arrangement in which a presbytery permits a teaching elder to labor out of bounds at a church setting that follows a different polity, diligent care should be taken to ensure that the minister, though he labors out of bounds, will be able to govern according to his Confessional Subscription. One particular area of concern is the third proverbial mark of a true church: the rightful exercise of discipline. The right of any PCA member to contest and appeal rulings of Church courts is part and parcel of Presbyterianism. In principle, it is unconstitutional, therefore unwise and improper, for PCA teaching elders to not have the accountability of jointly practicing discipline within the Church courts. It is one thing for a TE to labor out of bounds as a chaplain in the military, a missionary in the field, or an academic at a parachurch organization. For a TE to labor out of bounds as an overseer executing discipline over Christians in a church thrusts the matter to another level. Due to the irregularity of laboring out of bounds at a non-PCA church, a TE should be in an advisory role at the most. He should never vote in ecclesiastical matters. 

Since Scripture says that anyone who takes a vow should be diligent to carry it through quickly, it logically follows that taking a vow is imprudent knowing there are inherent obstacles to doing so. 

(Ecclesiastes 5:4-6) “When you vow a vow to God, do not delay paying it, for he has no pleasure in fools. Pay what you vow. It is better that you should not vow than that you should vow and not pay. Let not your mouth lead you into sin, and do not say before the messenger that it was a mistake. Why should God be angry at your voice and destroy the work of your hands?”

(Psalm 76:11) “Make your vows to the Lord your God and perform them; let all around him bring gifts to him who is to be feared.” 

Ministerial vows have a necessary bilateral aspect, not unlike matrimonial vows — so vows are “a two-way street.” Since a minister swears vows to rule and care for a congregation, and live out what he teaches, then that congregation likewise is to take vows to submit to his rule, encourage him, and observe his pattern of living to imitate his faith (I Corinthians 1:11, Hebrews 13:17). 

This is why Church order poses specific questions to the ordinand as well as to the congregation (BCO 21). Without both parties taking vows they are able to fulfill, the relationship is lopsided. 

Any teaching elders’ approval of “the general principles of biblical polity” (BCO 21-5.3) is not limited simply to what they verbally approve or what they teach at their church. Their “approval” extends to the actions and decisions they make in the administration of that church — in their everyday activities and in their Session meetings. If their “approval” of certain PCA polity standards does not encompass their actions, then whether or not we intend it, we would basically be saying that ministers’ actions do not have to actually line up with what they profess to believe: they can say one thing over here and do something completely different over there. The so-called “good-faith subscription” type of approval that doesn’t require our teaching elders’ actual conformity to the standards they profess would render that profession meaningless. It is reasonable to surmise that neither the early American Presbyterians nor the organizers of the PCA envisaged such a principial-practical disconnect for ministers when they employed the phraseology “do you approve …?” that obligates ministers in their Confessional Subscription. 

Theological principle cannot be abstracted from practical godliness without destroying both. To paraphrase Dr. Kelly Kapic, theology must be God-centered and yet man-sensitive, because Scripture’s divine revelations are “always interwoven” with concerns for human responses. Dr. Kapic tagged the term “anthroposensitive theology,” which entails “a refusal to divorce theological considerations from practical human application, since theological reflections are always interwoven with anthropological concerns” (A Little Book for New Theologians, Kelly Kapic, p. 47). 

In a different resource from his recommendation to North Georgia Presbytery, Dr. Taylor asserted, 

Promotion of the Purity of the Church
“Serious and honest subscription to our doctrinal standards is essential to the theological and ethical purity of the Church. The Presbyterian Church in America is a confessional Church. We are bound together in a common theological commitment. We are committed not only to theism, trinitarian Christianity, Protestantism, and Evangelicalism in general, but to the Reformed Faith in particular. This understanding is expressed in the Westminster Standards. … Moreover, while we have a presbyterian, representative, connectional church government delineated in our Book of Church Order, we do not have the more centralized, top-down system one would find in Scotland. In order to promote the theological purity of the Church, we must have office-bearers who subscribe knowledgeably and in good faith to the constitution of the Church. Otherwise there is no effective means of keeping the Church tied to her theological moorings, not only for future generations, but even in this generation.”
(“Practical Benefits and Dangers of Subscription,” L. Roy Taylor, The Practice of Confessional Subscription, ed. David Hall, p. 397) 

Promotion of the Peace of the Church
“For there to be peace in the Church, there must be widespread belief that the office-bearers of the Church are sincerely and knowledgeably committed to the constitution of the Church. The purity of the Church is essential to the peace of the Church. When the members of the Church are assured that the leaders of the Church understand, believe, appreciate, and promote the theology and government of the Church, the peace of the Church is enhanced. Peace in a Bible-believing confessional Church is not based on an ‘anything goes’ view of theology. Peace in such a Church is not secured by sacrificing biblical truth.”
(ibid., pp. 397-398) 

Promoting the Progress of the Church
“The Church does not exist for herself only, but rather as the primary agent through which the Kingdom of God grows within the world. The Church is commissioned to disciple the nations (Mt. 28:16-20; Mk. 16:15, Lk. 24:45-49; Jn. 20:21-23; Acts 1:8). The purity of the Church is an important aspect of the progress of the Church, because the Church must be sure of what she stands for and believes in order to propagate the faith. The peace of the Church is important to the progress of the Church as well. If the Church is constantly occupied with internal disputes and conflicts, her energies, time, and resources may be diverted from concentrating on evangelism and ministries of mercy. The subscription controversy, then, is not extraneous to the progress of the Church.”
(ibid., pp. 398-399)

Maintaining the integrity of office-bearers
“Serious, honest, and knowledgeable subscription is a matter of basic integrity. Subscription … to the Westminster Standards is not to be pro forma but rather ex animo; not a perfunctory act but a sincere declaration. This writer makes such a sincere declaration twice each year by signing the Book of Ministerial Obligation in his Presbytery as a PCA minister and by affirming in writing his commitment to the Westminster Standards as a professor at Reformed Theological Seminary. When anyone subscribes to the Westminster Standards integrity demands that his vow to ‘receive and adopt the Confession of Faith and Catechisms of this Church as containing the system of doctrine taught in the Holy Scriptures’ is a sincere, honest, and knowledgeable oath. On one hand it is not to be a mere sentimental attachment to a document that is important to our Church. It is not simply giving an affirmative answer to ritual questions in order to assume an ordained leadership role in the Church. On the other hand as Protestants, we do not require blind obedience to ecclesiastical authority. Nor do we elevate our confessional standards to the level of Holy Scriptures. We are to take our vows in integrity. …
Knowledgeable and honest subscription is fundamentally a matter of integrity. The Church must have a policy on subscription to the Westminster Standards that motivates candidates, officers, and ministers to be open and forthright in stating their views, while also guaranteeing that differences are dealt with biblically and thus fairly. Sessions and Presbyteries must take care that those whom they examine take their ordination vows knowledgeably, honestly, and sincerely.
The subscription issue is an important one with significant practical implications for the Church. Like most theological controversies, it has both benefits and dangers for the Church. May the God of truth so bless our churches as to resolve this matter in a way that is to God’s glory and the Church’s good.”
(ibid., pp. 400-401, 407)

In a booklet published in 2012 by P&R Publishing, which stands for Presbyterian & Reformed, Burk Parsons rigorously contended for the importance of not simply believing the church’s confessions, but also faithfully practicing and embodying them in Church officers’ deportment. 

“But the overflow of faith is the essential nature of faith itself — to encompass all of life by acknowledging, affirming, and applying the Christian doctrine we believe, confess, and proclaim. In the New Testament, James (1:22-25) repudiates the ‘worthless’ religion of those who are merely ‘hearers’ of the Word without being actual ‘doers’ of the Word. … James’ point is simple—if our mouths (v. 26) and our lives (v. 22) do not demonstrate the authenticity of pure and undefiled religion, then we are simply deceiving ourselves and deceiving our hearts (vv. 22, 26).”
(Why Do We Have Creeds? Basics of the Faith Series, Burk Parsons, pp. 9-10) 

“Christian doctrine, by its very nature, is an all-encompassing religion established on the entire system of doctrine, piety, and practice set forth in Scripture itself. It is crucial that we grasp this if we are to understand the nature of creeds, our use of creeds, and the church’s need for creeds. If we fail to see the all-encompassing nature of Christian doctrine, we certainly will not see the all-encompassing nature of creeds, which exist not only to affirm, confess, and proclaim the elementary matters of our faith, but to set forth the entirety of the doctrine, piety, and practice of the Christian religion. …
As Christians, we must not only affirm our creedal doctrine with a perfunctory lip service or a mere intellectual assent, we must know our doctrine with our minds and believe our doctrine to the core of our being. This is necessary so that with a good and sincere conscience we might affirm and apply the truths of our creeds as we seek to fulfill our chief end, namely, to glorify God and enjoy him forever.”
(ibid., p. 12) 

“The purpose of creeds is …
To remain steadfast through the ages until Christ’s return as one, holy, catholic, and apostolic church of Christ who believe, confess, and proclaim the pure and unadulterated Word of God and who rightly administer the sacraments of baptism and the Lord’s Supper, including our consistent exercise of church admonition, correction, and discipline. …
To confirm men according to the church’s doctrinal standard who have been elected to serve as officers of the church as well as to equip, examine, and prove those men who have been called as pastors and elders over the flock of God, and to ascertain their suitability to teach as they feed, care for, and pray with and for the sheep of Christ for whom he gave his life. …
To preserve the purity and, thereby, the peace and unity of the church visible as the outward witness of Christ and his elect bride, the church invisible, to the end that we might stand together as one family with one Father, one Lord, one faith, one baptism, unwaveringly according to and because of the truth, never in spite of, disregard for, or ignorance of it.”
(ibid., pp. 30-32) 

The central concern is, laboring out of bounds in a situation of presiding over a non-PCA congregation, how can any PCA teaching elders be true to “the obligations required of ministers at their ordination” and “sincerely receive and subscribe to the above obligation as a just and true exhibition of my faith and principles, and do resolve and promise to exercise my ministry in conformity thereunto,” and at the same time do any of the following poimenical activities? 

  1. Facilitate new members’ classes in which they guide Christians to covenant with a church community that either deviates from or denies the ecclesiastical connectionalism which pervades everything our ministers promise to uphold in their Confessional Subscription. 
  2. Request and accept the vows of Christians to submit to the discipline of a non-PCA ruling body that does not submit in accountability to the system of Presbyterian Church courts. 
  3. Vote on the discipline of members who have no access to Church courts should they have grounds to appeal such discipline and exercise that right, according to Presbyterianism. 
  4. Elect and appoint officers of the church, to oversee, shepherd and serve the Christians under their care, and present them before their congregation knowing that their members have no right to vote decently and in order according to the BCO’s prescribed form of call. 
  5. Convene with other teaching elders at Presbytery and/or General Assembly several times a year, functioning as credentialed Presbyters, voting on ecclesiastical matters while their own church members not have any representation in that Court, and influencing policies for PCA churches to follow, yet which they and their own church do not have to follow. 

It would appear that if granted permission to labor out of bounds, teaching elders could not carry on activities like these, especially for years, and at the same time uphold our Church’s standards. 

Dr. Taylor stated in his recommendations to the inquiring Presbytery, 

“When we require that a man be called to a ‘definite work’ this distinguishes Presbyterians from others who practice Episcopal government. In branches of the Church that use an Episcopal government, one may be ordained first and receive a call to a specific ministry later, when so assigned by the bishop. … The occasion for our discussion has been the admittance of two ministers to PCA labor outside our ecclesiastical bounds on the staff of an independent Anglican Church. The term ‘ordinarily’ is used in the BCO to indicate usual procedures that are to be followed, but also to indicate that there are some extenuating circumstances that may be considered to allow for variations from the usual procedure (BCO 1-6, 5-2, 13-5, 14-1, 15, 18-2, 20-1, 21-1, 21-4, 28-5, 39-3, 40-3, 41-2, 41-5, 52-3, 56-3). …
In Calvin’s Necessity of Reforming the Church, he argued that the Church needed to be reformed in; 1) theology, 2) worship, 3) church polity. Though Calvin, restored presbyterian church government in Geneva after over one thousand years of its neglect, and Knox instituted presbyterian church government in the Church of Scotland, neither Calvin nor Knox regarded presbyterian church government as essential to the existence of the Church (esse), but necessary to the well-being or perfection of the Church (plene esse). 1 Consequently, when some Calvinists were offered bishoprics in the Church of England, both Calvin and Knox advised them to accept a bishopric, if one’s conscience were not bound, in order to reform the Church of England first in its theology and worship, and then later, in its polity. 2 One such minister, William Grindal, was even appointed Archbishop of Canterbury, by Elizabeth I! Our BCO advocates the plene-esse view in its statement, ‘the scriptural doctrine of Presbytery is necessary to the perfection of the order of the visible Church, but is not essential to its existence’ (BCO 1-7). That plene-esse view is also seen in the BCO-8-7 requirement that a PCA minister laboring outside the bounds of presbytery must have the right to teach, preach and practice the Reformed Faith. That plene-esse view is also expressed in our ordination vow that we hold that the form of government and discipline of the PCA are in conformity with the general principles [emphasis added] of Biblical polity (BCO 21-5, 24-5, Q. 3).” 

We are now looking to the situation of John Calvin advising 16th-century Calvinistic ministers to seek ordination in the 16th-century Anglican Communion in England as a frame of reference to address the question as to whether it is constitutional/in order/proper for one of our presbyteries to ordain a PCA teaching elder to a call from a modern Anglican setting. His theory is that such ecumenical cooperation could be an opportunity to engender reform in a non-Reformed polity. 

According to Dr. Taylor’s recommendation, the issue which concerned that Presbytery was the question of ordaining pastors in the PCA for them to be allowed to work in an “independent episcopal polity” — not Presbyterians who were seeking ordination in an independent Anglican Church. The difference in historical setting does not necessarily disqualify this as an example that we might follow, but assuming a one-to-one comparison of the 16th century to today, we still face the puzzle of ordaining our own ministers to labor out-of-bounds in non-PCA churches — not ministers ordained in other denominations seeking calls in our Church. Would we accept pastors retaining ordination in other denominations into calls within our PCA churches? Why or why not? 

We already have enumerated the ways in which a member of a non-PCA church could become ordained as a minister in our denomination and be allowed to labor out of bounds, performing activities in a non-PCA call with little to no oversight at his non-PCA church, while he enjoys Presbyterian voting rights and sitting on committees in our Presbytery, having input into how things are done in our denomination’s churches but which wouldn’t obligate him and his church. 

In such a scenario where we would ordain a man as a TE who would not be a member of the PCA but of an unpresbyterated, prelatic church, who would be more likely to be influencing whom? 

It also would be enlightening to learn what circumstances a presbytery would find it “extenuating” to ordain men to work at churches that are not ours, indefinitely, especially men who are not PCA members, especially when there are PCA churches all over the country that need ordained pastors.

Dr. Taylor concluded, 

“In short, to maintain that no extraordinary call may be approved to an independent Anglican Church, in my opinion, goes beyond the requirements of our constitution (BCO 1-7, 21-5, 24-5, Q. 3) and is contrary to the historical bene-esse view even of jure-divino presbyterianism.
In light of the above discussion, it is my recommendation that this committee seek to formulate no further requirements on out-of-bounds calls than those which the BCO already stipulates and that each extraordinary call be considered on its own merits.” 

In this Church member’s opinion, our venerable third GA Stated Clerk’s written opinion so far does not satisfactorily resolve the question of how, in a polity that includes principles discordant with those of the PCA, a teaching elder could truthfully fulfill his Confessional Subscription found in BCO 13-7 and 21-5. This is especially problematic with how a PCA TE in a non-PCA setting would be able to vote for the discipline of members of his non-PCA church who do not have appellate standing at the PCA court where the TE is a member, which exercise would seem to be abuse and overreach of his Presbyterian authority, and thus it might be of his Presbytery as well. 

To look at a much more recent example, the PCA currently has four teaching elders laboring out of bounds at one independent church, and since that church was the first call for three of those teaching elders upon ordination, three of them were ordained expressly to pastoral services at a church of another denomination (over against the judicial ruling adopted by the Fourth GA). 

Three of these four teaching elders were recently instructed by their Presbytery, as a condition of continuing to labor out of bounds, to bring the constitution of their church into compliance with the BCO as it concerns congregational voting rights. In the newly adopted bylaws, the Session led by our own TEs shall nominate pastoral candidates, and they may effect classes in their eldership.

Article IV. Elders (The Session) Section 4.03. Election and Term.
“Elders may be divided into classes. … The Session may establish any classes and terms of office. The Senior Pastor and any Associate Pastors (Teaching Elders) shall be nominated by the Session, or a committee of Session members, examined by the Session, elected and called by the members of Saint Andrew’s Chapel.” 

Instead of ensuring congregational oversight and parity between elders, these bylaws effectively stratify the Session from the congregation and stratify the teaching elders from the ruling elders. Such provisions would facilitate what D. Douglas Bannerman would have identified as “prelatic developments,” making it easy for our out-of-bounds Presbyterian teaching elders to establish a hierarchy within the governance structure of their particular church, were they inclined to do so. 

This hybrid governance model also would enable our PCA officers to offload certain poimenical responsibilities to unaccountable members of their ruling body, then use that unchecked body to insulate themselves from Presbyterian accountability something of an ecclesiastical “sweet spot.” 

For any presbytery to continue permitting its officers to routinely labor in this conflict of interest would seem to put them in perpetual undue temptation. Consider the insights Bannerman pressed: 

Part VI. From Antioch to Rome—The Gentile Christian Church
Chapter IV. Organization of Apostolic Church in Second Period of Its History
3. Relation of the elders to each other.
“That a leading presbyter might sometimes ‘love the first seat’ among his brethren, and make an unwarrantable use of the influence and authority connected with it, was to be expected, human nature being what it is even in Christian men. Instances of this kind were to be found in the annals of the Jewish synagogue elderships, and of ‘the presbytery of Israel’ in Jerusalem. In what is perhaps the latest document of the New Testament, the Third Epistle of John, the aged apostle speaks with strong reprehension of ambitious tendencies of this sort on the part of leading men in some of the Churches of Asia. ‘I wrote somewhat unto the Church; but Diotrephes, who loveth to have the pre-eminence among them (or over them …), receiveth us not. Therefore, if I come, I will bring to remembrance his works which he doeth, prating against us with wicked words; and not content therewith, neither doth he himself receive the brethren, and them that would he forbiddeth, and casteth them out of the Church. Beloved, imitate not that which is evil, but that which is good.’”
(The Scripture Doctrine of the Church, D. Douglas Bannerman, p. 553)

And also what John Murray wrote: 

Chapter 28. The Form of Government
“The principle of parity is to co-ordinate with that of plurality. Strictly speaking there can be no plurality if there is not parity. For if one is in the least degree above the others, then, in respect of that hegemony, there is no longer plurality. Plurality applies to all government of the church, and there must therefore be parity in the plurality. There is not the slightest evidence in the New Testament that among the elders there was any hierarchy; the elders exercise government in unison, and on a parity with one another.
This principle has oftentimes suffered eclipse within the presbyterian fold. It has come to expression within presbyterian churches by the entertaining of the notion that to the minister of the Word belongs priority or pre-eminence in the government of the church. It is true that the minister as a teaching elder has his own distinctive function in the preaching and teaching of the Word. He labours in the Word and doctrine. It is natural and proper that his knowledge and experience should be given due respect in the deliberations which must be undertaken by the elders in the exercise of the government of the church. But it cannot be too strongly emphasized that, in respect of ruling, the minister of the Word is on a parity with all the others who are designated elders. When this is discarded, then there ensues that type of clerical hierarchism which has reached its logical outcome in what is known as hierarchical episcopacy, and it is the first step in the abandonment of the institution of Christ. Ministers of the word in presbyterian denominations are not immune to the vice of autocracy, and they are too ready to grasp at an authority that does not belong to them. This evil, which has marred the witness of churches professing presbyterian government, only illustrates the need for constant vigilance, lest the elementary principles of presbyterian government be violated and desecrated. It is not only by erroneous theory that presbytery is prejudiced, but also by practice which subtly annuls the theory professed. …
We have found that the kind of government set forth in the New Testament is that of a plurality of elders or bishops exercising oversight on a parity with one another. It is all-important to take account of the fact that it is on the local level that this must, first of all, be applied. It is in the local assembly, or congregation of God’s people, that the ordinances of Christ’s appointment for his church are regularly administered. The importance of the local congregation is therefore paramount and it is in the local congregation that the presbyterian principle must first be exemplified. If it is not preserved and practised at this point, it is not in operation at all.”
(Collected Writings of John Murray Volume Two: Select Lectures in Systematic Theology, pp. 346-348) 

Dr. Taylor’s recommendation to North Georgia Presbytery’s inquiry quoted some of Calvin’s The Necessity of Reforming the Church. If we are to use this item as historical evidence to support formal cooperation with non-PCA churches through clerical loans via BCO 8-7, then it behooves us to take into account the broader context of what exercised Calvin which he protested in that missive. In 1543, when Calvin was age 34, he addressed written representation to the emperor, which exposed the ghastly ramifications within the Roman Catholic Church caused by their seizure of the congregational right to presbyterian election — a like usurpation which, in fact, has occurred under the auspices of PCA teaching elders laboring out-of-bounds in diluted accountability at an independent church, an expropriation that could happen again in alien calls with our own pastors. 

Seriously to Undertake The Task Of Restoring The Church.
Presented In The Name Of All Those Who Wish Christ To Reign.
Not the least important branch of ecclesiastical government is the due and regular election and ordination of those who are to rule. The Word of God furnishes a standard by which all such appointments ought to be tested, and there exist many decrees of ancient Councils which carefully and wisely provide for every thing which relates to the proper method of election. Let our adversaries then produce even a solitary instance of canonical election, and I will yield them the victory. We know the kind of examination which the Holy Spirit, by the mouth of Paul, (Epistles of Timothy and Titus,) requires a pastor to undergo, and that which the ancient laws of the Fathers enjoin. At the present day, in appointing Bishops is anything of the kind perceived? Nay, how few of those who are raised to the office are endowed even slenderly with those qualities without which they cannot be fit ministers of the Church? We see the order which the Apostles observed in ordaining ministers, that which the primitive Church afterwards followed, and, finally, that which the ancient Canons require to be observed. Were I to complain that at present this order is spurned and rejected, would not the complaint be just? What, then, should I say that every thing honorable is trampled upon, and promotion obtained by the most disgraceful and flagitious proceedings? The fact is of universal notoriety. For ecclesiastical honors are either purchased for a set price, or seized by the hand of violence, or secured by nefarious actions, or acquired by sordid sycophancy. Occasionally even, they are the hire paid for panderism and similar services. In short, more shameless proceedings are exhibited here than ever occur in the acquisition of secular possessions. …
As it would shame our adversaries to deny these facts, (for in a matter so clear, what could they gain by the denial?) they quarrel with us, first, concerning the right and power, and, secondly, concerning the form of ordination. They quote ancient canons, which give the superintendence of this matter to the bishops and clergy. They allege a constant succession by which this right has been handed down to them, even from the apostles themselves. They deny that it can be lawfully transferred elsewhere. I wish they had, by their merit, retained a title to this boasted possession. But if we consider, first, the order in which for several ages bishops have been advanced to this dignity, next, the manner in which they conduct themselves in it, and, lastly, the kind of persons whom they are accustomed to ordain, and to whom they commit the government of churches, we shall see that this succession on which they pride themselves was long ago interrupted. The ancient canons require, that he who is to be admitted to the office of bishop or presbyters shall previously undergo a strict examination, both as to life and doctrine. Clear evidence of this is extant among the acts of the fourth African Council. Moreover, the magistracy and people had a discretionary power (arbitrium) of approving or refusing the individual who was nominated by the clergy, in order that no man might be intruded on the unwilling or not consenting. ‘Let him who is to preside over all,’ (says Leo, Ep. 90.,) ‘be elected by all; for he who is appointed, while unknown and unexamined, must of necessity be violently intruded.’ Again, (Ep. 77.,) ‘Let regard be had to the attestation of the honorable, the subscription of the clergy, and the consent of the magistracy and people. Reason permits not any other mode of procedure.’ Cyprian also contends for the very same thing, and, indeed, in stronger terms, affirming it as sanctioned by Divine authority, that the priest be elected in presence of the people, before the eyes of all, that he may be approved as fit and worthy by the testimony of all. This rule was in force for a short time while the state of the church was tolerable; for the letters of Gregory are full of passages which show that it was carefully observed in his day. …
They maintain that Christ left as a heritage to the apostles, the sole right of appointing over churches whomsoever they pleased, and they complain that we, in exercising the ministry without their authority, have, with sacrilegious temerity, invaded their province. How do they prove it? Because they have succeeded the apostles in an unbroken series. But is this enough, when all other things are different? It would be ridiculous to say so; they do say it, however. In their elections, no account is taken either of life or doctrine. The right of voting had been wrested from the people. Nay, even excluding the rest of the clergy, the dignitaries have drawn the whole power to themselves. The Roman Pontiff, again, wresting it from the provincial Bishop, arrogates it to himself alone. Then, as if they had been appointed to secular dominion, there is nothing they less think of than episcopal duty. In short, while they seem to have entered into a conspiracy not to have any kind of resemblance either to the Apostles or the holy Fathers of the Church, they merely clothe themselves with the pretense that they are descended from them in an unbroken succession; as if Christ had ever enacted it into a law, that whatever might be the conduct of those who presided over the Church, they should be recognized as holding the place of the Apostles, or as if the office were some hereditary possession, which transmits alike to the worthy and the unworthy. And then, as is said of the Milesians, they have taken precautions not to admit a single worthy person into their society; or if, perchance, they have unawares admitted him, they do not permit him to remain. It is of the generality I speak. For I deny not that there are a few good men among them, who, however, are either silent from fear, or not listened to. From those, then, who persecute the doctrine of Christ with fire and sword, who permit no man with impunity to speak sincerely of Christ, who, in every possible way, impede the course of truth, who strenuously resist our attempt to raise the Church from the distressed condition into which they have brought her, who suspect all those who take a deep and pious interest in the welfare of the Church, and either keep them out of the ministry, or, if they have been admitted, thrust them out — of such persons, forsooth, it were to be expected that they would, with their own hands, instal into the office faithful ministers to instruct the people in pure religion! …
Were I to follow out all the flagitious corruptions of ecclesiastical government, I should enter an interminable forest. Of the lives of the priests, for many reasons, I at present decline to speak; but there are three vices of an intolerable description, on which each individual may reflect for himself: First, Disregarding the character of a holy vocation, clerical offices are everywhere acquired either by violence or by simony, or by other dishonest and impious arts: Secondly, The rulers of the Church, in so far as regards the performance of their duties, are more like empty shadows or lifeless images than true ministers; and, Thirdly, When they ought to govern consciences in accordance with the Word of God, they oppress them with an iniquitous tyranny, and hold them in bondage by the fetters of many impious laws. Is it true, that, not only in contempt of the laws of God and man, but in the absence of everything like a sense of shame, foul disorder reigns in the appointment of Bishops and Presbyters? that caprice assumes the place of justice, simony is seldom absent, and, as if these were evils of no consequence, the correction of them is deferred to a future age?”
(The Necessity of Reforming the Church, To The Most Invincible Emperor Charles V., And The Most Illustrious Princes And Other Orders, Now Holding A Diet Of The Empire At Spires

What could have fueled such boldness by the 34-year-old Calvin toward royalty? Perhaps he was emboldened by “a heart for devotion, doctrine and doxology,” a healthy reprehension of clerical abuses he had witnessed, and pondering Psalm 119:46-47: “I will also speak of your testimonies before kings and shall not be put to shame, for I find my delight in your commandments, which I love.” In any case, if our Reformed titan had instead aimed this salvo at us modern Presbyterians, we may be too genteel for Calvin’s idiolect and our tribunals might dismiss his choice of words as “imprudent” or “intemperate language.” But that would be futile to nullify the facts of his message. 

One PCA TE who has enjoyed an out-of-bounds call at a non-PCA church since 2008 expressed, 

“The entirety of Calvin’s ministry was established fundamentally on the Word of God. In accordance with the Reformation credo ad fontes, ‘to the sources’ (particularly to the only infallible source), Calvin’s Institutes was a summary of the Christian religion according to Scripture. … Through the years, as I have spoken with fellow Reformed pastors throughout the world, I have often sensed their grief over the multitudes of so-called Calvinists who may have worked out some of the doctrinal difficulties of one point or another but have not even begun to grasp all the magnificent nuances of Calvin’s Calvinism. Such Calvinism is engendered and shaped by Scripture alone—and that makes it a Calvinism that begins with God, teaches us about God, and directs our hearts and minds back to God according to the way He deserves, demands, and delights in our worship of Him and our obedience to Him. This is the threefold foundation of Calvin’s Calvinism: devotion, doctrine, and doxology—the heart’s devotion to the biblical God, the mind’s pursuit of the biblical doctrine of God, and the entire being’s surrender to doxology. …
A true Calvinist is one who strives to think as Calvin thought and live as Calvin lived—insofar as Calvin thought and lived as our Lord Jesus Christ, in accordance with the Word of God.”
(John Calvin: A Heart for Devotion, Doctrine & Doxology, Chapter 1: “The Humility of Calvin’s Calvinism,” Burk Parsons, pp. 5-6) 

“When the sixteenth-century pastor John Calvin wrote an all-encompassing systematic theology of the Christian faith, he titled his work, in Latin, Institutio Christianae Religionis, which can be translated Institutes of Christian Religion, or Institutes of Christian Piety. For Calvin a man’s doctrine is the foundation of his entire religion, and a man’s religion is not isolated to one segment of his life but has implications for all of life. We cannot restrict our doctrine as many attempt to do. Rather, our doctrine will, by its very nature, branch out into every sphere of Christian piety and practice. In other words, a man’s doctrine is a man’s life. What we believe inescapably influences what we think, what we do, and even our motives of why and how we think it and do it.”
(Why Do We Have Creeds? Basics of the Faith Series, Burk Parsons, p. 11)
“However, when we say our belief about God affects everything, we are not only referring to our beliefs about God’s attributes but our beliefs about all of God’s revelation to us in his holy Word, the Scriptures of the Old and New Testaments, which are the foundation and fountain of our entire religion. …
Our belief about God informs every other belief. And while God has revealed himself generally in creation, it is only what God has revealed specially to us in his Word that guides us finally and infallibly—without error. God gave us himself and everything that comes with knowing him, which entails knowledge of ourselves and others, of sin and salvation, of life and death, of Satan and our Savior. His Word is our only infallible guide, and from it we obtain true and saving knowledge about our all-encompassing religion. As such, it is from God’s Word alone that we derive the doctrine that informs us and that, in turn, must inform our creeds. …
As he indwells us, the Holy Spirit teaches us through the very means that he himself has not only permitted, but through the means of men he has called and gifted for the church today, namely, pastors and teachers (Eph. 4:11). In his sovereign wisdom God has not only given us his truth by his grace, but he has given us the means to learn his truth as we, by his grace, strive to believe, confess, and proclaim his truth fully and entirely. Paul describes this in Ephesians 4, making perhaps the most poignant biblical case for the necessity of creeds. … What Paul explains to the growing, world-advancing church at Ephesus is precisely what Jesus teaches in the Great Commission as he commends to us an all-encompassing faith and life that is consumed with learning to ‘observe’ all that Jesus commanded us as his disciples at his feet and disciple makers to the nations. Simply put, to observe all Jesus’ teaching we must believe, confess, and proclaim his truth in all our doctrine, piety, and practice, not as ‘children, tossed to and fro by the waves and carried about by every wind of doctrine’ but as mature disciples of Jesus Christ standing firm on the doctrine of Scripture. In order to do this we must strive to learn and remember the entirety of the doctrine of Scripture that Jesus himself affirmed, confessed, and proclaimed. As sinful creatures, the best way we know to do this is to search Scripture as the Bereans did (Acts 17), collectively affirm what Scripture teaches as the council at Jerusalem did (Acts 15), and declare it and disseminate it in every way possible as the apostles did (Acts 15:22-34), using a format by which we can more easily learn and remember, just like Paul did wherever he went (Acts 15:30; 19:8; 26:23). …
So whether we have in mind the only inspired and infallible creedal formulations in Scripture itself or the uninspired and fallible creedal formulations such as the Apostles’ Creed, the Nicene Creed, the London Baptist Confession of Faith, the Three Forms of Unity of the Dutch Reformed churches consisting of the Heidelberg Catechism, Canons of Dordt, and Second Belgic Confession, or the confessional standards to which I heartily subscribe, the Westminster Confession of Faith and Catechisms, it is crucial that we understand the church’s God-given duty to be a faithful steward and guardian of the one and only faith delivered to the saints in order to provide the church of all generations with carefully worded, concise summaries of the doctrine of Scripture.”
(ibid., pp. 14-15, 26-29) 

If we wish to learn how subscription has entailed not only verbally approving, but also carrying out one’s ministry in conformity to the standards that are being subscribed, especially the principles of church government, we can look early in Presbyterian history. 

1690, in the Church of Scotland, when the Glorious Revolution was achieved and Presbyterianism was safe from the “Killing Times,” the Westminster Confession of Faith was again ratified as “the public and avowed confession of this Church.” The formal oral subscription was supplemented then by a requirement for written subscription to the Confession (“all probationers licensed to preach, all intrants [sic] into the ministry, and all other ministers and elders received into communion with us” were “obliged to subscribe their approbation of the Confession of Faith”). The precise formula for this subscription was fixed by the Assembly in “The Act for Settling the Quiet and Peace of the Church, 1693: Anent Uniformity of Worship.” It stated “that no person be admitted or continued for hereafter, to be a minister or preacher within this Church, unless that he … subscribe the Confession of Faith ratified in the aforesaid fifth Act of the second session of this Parliament, declaring the same to be the confession of his faith, and that he owns the doctrine therein contained to be the true doctrine which he will constantly adhere to: As likewise that he owns and acknowledges Presbyterian Church government … to be the only government of this Church, and that he will submit thereto, and concur therewith, and never endeavour, directly or indirectly, the prejudice or subversion thereof.” The following year, a new subscription formula was enacted which required the ordinand to “own the doctrine therein contained to be the true doctrine, which I will constantly adhere to.” (N. M. de S. Cameron, et al eds., Dictionary of Scottish Church History and Theology, p. 805, s.v. “Subscription, Confessional,” by I. Hamilton)

Ligon Duncan points out, 

Subscription to the Westminster Confession, 1647-present
1711. Soon after the Anglo-Scottish Treaty of Union (1707), a new formula was adopted. Various reasons have been suggested for its implementation, but the general consensus is that it was intended to strengthen the Kirk’s current commitments to the Confession so as to protect herself from any potential influx of episcopalians. [See I. Hamilton, The Erosion of Calvinist Orthodoxy (Edinburgh: Rutherford House, 1990), 4-5.]
Act 10 of the Assembly (1711) provided that ministers and probationers would make vows in response to questions, and then subscribe the Formula. The second question of the ordination vow is virtually that which is still employed today in the Free Church of Scotland: ‘Do you sincerely own and believe the whole doctrine contained in the Confession of Faith … to be founded upon the Word of God; and do you acknowledge the same as the confession of your faith?’”
(“Owning the Confession: Subscription in the Scottish Presbyterian Tradition,” J. Ligon Duncan III, The Practice of Confessional Subscription, ed. David Hall, pp. 116-117)

The Formula referenced here to be subscribed read: 

“I _do hereby declare, that I do sincerely own and believe the whole doctrine contained in the Confession of Faith approved by the General Assemblies of this National Church, and ratified by law in the year 1690, and frequently confirmed by divers Acts of Parliament since that time, to be the truths of God; and I do own the same as the confession of my faith: As likewise, I do own the purity of worship presently authorised and practised in this Church, and also the Presbyterian government and discipline now so happily established therein; which doctrine, worship and Church government, I am persuaded, are founded upon the Word of God, and agreeable thereto: And I do promise, that, through the grace of God, I shall firmly and constantly adhere to the same, and to the utmost of my power, shall in my station assert, maintain and defend the said doctrine, worship, and submit to the said discipline and government, and never endeavour, directly nor indirectly, the prejudice or subversion of the same: And I do promise, that I shall follow no divisive course from the present establishment in this Church: Renouncing all doctrines, tenets, and opinions whatsoever, contrary to or inconsistent with the said doctrine, worship, discipline, or government of this Church.”
(Cited in J. Cooper, Confessions of Faith and Formulas of Subscription, p. 66)

In America, the Presbytery of Donegal was formed in 1732. Their method of subscribing the Confession of Faith was as follows: 

“I, having seriously read and perused the Westminster Confession and Catechisms, do declare in the sight of God and all here present, that I do believe, and am fully persuaded, that so far as I can discern and understand said Confessions and Catechisms, they are, in all things, agreeable to the word of God, taking them in the plain and obvious meaning of the words: and accordingly I do acknowledge them as the confession of my faith, and do promise, through divine assistance, for ever to adhere thereto. I also believe the Directory for the exercise of worship, discipline, and government, commonly annexed to said Confession, to be agreeable to the Word of God, and I do promise to conform myself thereto in my practice, as far as in emergent circumstances I can attain unto.” 

Ligon Duncan continues, 

Observations and Conclusion
“It is perhaps now self-evident, even on the basis of this all-too-brief review of the highlights of the practice of subscription in the Scottish tradition, why this is so vital a thing to be studied for those who are interested in seeing a settlement of this issue in conservative American Presbyterianism. The lessons and road-signs of the past are here ignored at our own peril. In light of these historical markers, the following preliminary observations and conclusions are offered: some relating to the Scottish legacy, some concerning the current American Presbyterian dilemma. …
It is evident from the Scottish practice, that subscription is not the answer if one is seeking to create theological unity out of diversity. Rather it is an instrument of enforcement and preservation of existing orthodoxy and consensus. Any who see ‘strict subscription’ as a panacea for the conservative Presbyterian Churches in America, hence, have the cart before the horse. First there must be a consensus to guard, before one discusses how best to guard it. …
There is good evidence from Scottish Church history to show that loss of confessional authority (in either the act of approval or formula of subscription) does not increase freedom, but rather it diminishes it. Having been freed from meaningful adherence to an established formulation, one finds oneself captive to the tyranny of a fifty-percent plus one majority of any General Assembly—all the worse for its changeability. Though relaxation of approval acts or subscription formulas may increase the liberty of those within a particular communion who are out of accord with certain specifics of the confession (and hence initially allow for a greater range of theological diversity), at the same time such a procedure has a tendency to restrict (and exclude from the process) those remaining in the communion who adhere to former and more ‘narrow’ views (from the standpoint of the majority); indeed eventually excluding them from the privilege of liberty of conscience. …
As to the core of doctrine in the Confession, it is clear that classic federal theology is so much a part of the warp and woof of the Westminsterian system, that removal of any component of its covenant theology would bankrupt the very idea of a ‘Westminsterian system of theology’ of any meaning. Therefore, those who have expressed reservations about the Confession’s covenantal system (in both the nineteenth and twentieth centuries) are not so much questioning particular doctrines of the Confession as they are the very heart of its theological system. …
Finally, until we cease to be satisfied with mere assent or acquiescence to whatever theological system or confession we propone, and begin to demand a personal embrace, belief, and owning of that confession on the part of all candidates and officers, we will not be safe from the waves of theological sea-change still breaking upon the shores of the Church today.”
(“Owning the Confession: Subscription in the Scottish Presbyterian Tradition,” J. Ligon Duncan III, The Practice of Confessional Subscription, ed. David Hall, pp. 122, 124-126)

Dr. James Bannerman, a distinguished professor of practical theology at the University of Edinburgh, was among the hundreds who left the Established Church for the Free Church in 1843. In The Church of Christ: A Treatise on the Nature, Powers, Ordinances, Discipline, and Government of the Christian Church, a two-volume compilation of his lectures to ministerial students at New College, Bannerman mused on the difficult questions surrounding Presbyterian churches cooperatively sharing ministers with non-Presbyterian churches. Although he obviously lived in a different country on a different continent in a different century, many of his timeless musings are quite germane for the substantive question of how a minister’s competing obligations toward his denomination and toward his particular church might render his position untenable. 

Appendix A. Bearing of Scriptural Principles on the Lawfulness and Duty of Union between Separate Churches
Extract from Speech on the Union Question, Jan. 9, 1867
“The acknowledgement of any religious society as a living branch of the Vine lays upon us instantly the duty of treating it as a Church of Christ. When God giveth opportunity, the recognition of any religious body as a Church of Christ, without doubt, lays upon us a primâ facie obligation to go forward to union and co-operation, unless it can be made out that union and co-operation are impossible without sin on one side or other. And now comes the second question that meets us in the case of union for common objects between individual Christians, and which equally meets us in the case of union for common objects between Churches: Are the methods of co-operation which such union implies,—are the principles and ways of joint working which are involved in it, lawful or unlawful, scriptural or unscriptural? Can the Churches, and the members and office-bearers of the Churches, work together in union without the sacrifice of conscience or principle on either side? This is the only question that remains to be answered, in order to determine the matter of duty as to union in those cases where Providence offereth opportunity, and where Churches equally recognise each other as Churches of Christ. If the way and mode of that joint action which union necessitates be in themselves lawful, the union itself must not only be lawful, but a duty; if there is nothing required by such incorporation in the shape of unscriptural sacrifice, either as to belief or practice, then there is nothing to stand in the way of that duty which we owe to the one body of Christ—the duty, namely, of joining ourselves to those who are His members as well as we. If, on the other hand, the necessities of action in common which the union of Churches implies should impose on either party a compromise of creed or duty amounting to what is wrong, then the separation between them, although itself implying sin on one side or other, cannot be lawfully healed by means of a union which would bring along with it other sin. The controversy about union can only be settled by the settlement of this question. Where the first point must be taken for granted, where the Churches, as in the present instance, recognise each other as equally branches of the one Church of the Redeemer, and when this acknowledgement primâ facie involves in it the fundamental duty of showing their oneness in Christ by the visible realization of it, nothing can be a lawful or Scriptural bar to union, except the actual proof that the administration of doctrine, worship, and government by Churches in common would impose upon ministers or members the necessity of doing what was unlawful and unscriptural. Less than this cannot stand in the way of the positive obligation lying upon Churches of Christ to confess, and to act on the confession, that those who are one with Christ are also one with each other. Considerations of expediency, of feeling, of advantage on one side or other, cannot be listened to when, first of all, a question of duty must be heard. It is time that we were studying the Word of God and the standards of our Church, in order to ascertain the great principles which must rule and decide this question of duty.
So far as I have been enabled to understand the question, these are the general principles which, sooner or later, must, in their application to the case in hand, determine the duty of union between the negotiating Churches. We are justified in taking for granted, on all hands, the mutual acknowledgement, cordially made and responded to, that the religious bodies now contemplating union are true Churches of Christ, living branches of the one living Vine, living members of the one living body of which Christ is the Head. The only question that can be raised is the second of those to which I have adverted,—namely, whether, admitting them to be true Churches of Christ, there is, or is not, in a common action on the part of these Churches, in such a joint administration of doctrine, worship, and government, as the contemplated union implies, anything that would lay upon you as a minister, or myself as a member, a necessity of doing what we believed to be unlawful and wrong? If union implies such a necessity, it is a sin; if union imposes no such necessity, it is a Scriptural duty. This is really the hinge of the controversy about union. I may admit a religious society to be a true Church of Christ. But that religious society may be acting upon principles, and necessitating its office-bearers and members, so long as they are in communion with it, to act on principles which involve what is unscriptural and wrong. Notwithstanding of its grievous defections and shortcomings, I cannot refuse to acknowledge that the Established Church of Scotland is a Church of Christ. But I would not be a minister of that Church, because, by my tenure of office as a minister, I should feel that I gave my consent to its Erastian compact with the State, and was bound, in consequence, to do and sanction things which to me would appear to be sin. I believe that the Church of England is a Church of Christ; but I could not be a minister of that Church, because my position as such would compel me to own a creed that is wide enough to cover both Romanism and Rationalism, and to act under a form of government which I do not find in the Word of God. I believe that the Congregational body is a true Church of Christ, and I honour it as sound in the great truths of the Gospel. But I would not be a minister of that Church, because, as such, I should be forced to act upon principles of Church government, which to me, as a Presbyterian, cannot be made to consist with those Church principles which I recognise in Scripture. In all these cases, it is not because they are not churches of Christ that I refuse to unite with them, but because union would put me in a position in which I should be compelled to acknowledge or to do what, with my views, I felt to be unscriptural and wrong. Would any such acknowledgement or action, to which my conscience could not consent, be forced upon me in consequence of union being realized between the negotiating Churches? Would a common administration of Word and ordinance, of worship and government, upon the grounds and according to the principles contemplated in the union, force me to own doctrines I could not conscientiously own, or to act in a way that I felt to be unlawful? This is really the question on which the matter of duty depends. … There are no more than two ways in which a Church can meet and refuse the call of duty that summons them to union with another Church, and demands that they shall show publicly their oneness in Christ by actually being one among themselves. If, first, a Christian Church can say that the party to whom they are called upon to join themselves is not itself a Christian Church, then indeed the summons falls to the ground. This is an answer to the call to union which no one in the present instance will venture to prefer. Or, secondly, if a Christian Church can say, if it can show that union for the joint administration of Word and Sacrament, of government, worship, and discipline, in a Church, lays upon ministers and members the necessity of some compromise of truth, or some surrender of duty, then this too would furnish a sufficient answer, and union, however desirable, would cease to be lawful or Scriptural. And the question substantially comes to this: Can such an allegation be truly pleaded? Is there, in the first place, any compromise of truth, any sacrifice of the doctrines we believe and hold, any denial of one article of our faith, demanded or expected in the event of the union that is contemplated? Or is there, in the second place, under the restraint of such union, any obligation or necessity laid upon us to adopt a line of practical conduct other than we would take without union, or to act in a way unscriptural, and by a rule we would not sanction, if we continued as a separate Church?”
(The Church of Christ, James Bannerman, pp. 862-865) 

Although some cursory etymology shows that the familiar term “conflict of interest” does seem to have existed at least by Bannerman’s time, apparently the phrase wasn’t widely used yet, because if he had known of it then we probably could expect to find it mentioned in his 1867 union speech. 

In the two-volume Constitutional History of the Presbyterian Church in the United States of America, Charles Hodge wrote, 

“If then, explicit official declarations and the actual administration of discipline can decide the question, it is clear that our Church has always required adherence to the system of doctrine contained in the Westminster Confession of Faith as a condition of ministerial communion. From the adopting act of 1729 to the present hour, there is not a line upon our records which, either directly or indirectly, teaches that nothing beyond the essential and necessary doctrines of the gospel was to be required of its ministers. On the contrary the very ambiguity of the adopting act was the occasion of that doctrine being repudiated, and a strict adherence to the Confession enjoined with a frequency and clearness which otherwise would not have been called for.”
(Cited in The Practice of Confessional Subscription, ed. David Hall, pp. 144-145) 

Hodge did discuss certain areas of the Confession which in the historical setting were permitted to be excepted by ministers, and the reason we mention this here is not necessarily to deal with the question of what are acceptable exceptions today, rather, how conservative American Presbyterians viewed the relationship between subscription in a minister’s word to his adherence in his action. 

George Knight has recounted about the heritage of the PCA and admonishes our denomination, 

“An overwhelming consensus was maintained with regard to the meaning and significance of adopting the confessional standards in the American Presbyterian Church until the decline and departure of the 1900s. It is that earlier, consistent position that continues as the spiritual heritage of such churches as the Presbyterian Church in America (PCA), the Orthodox Presbyterian Church, and others. It must be followed and maintained today.
What is that heritage? It is: (1) that each officer adopts the Confession and Catechisms as his own confession of faith; (2) that each officer by adopting the confessional standards acknowledges that all the articles are essential and necessary to the system of doctrine, (3) that each officer in affirming that the confessional standards contain the system of doctrine taught in the Holy Scriptures is assenting ‘to the whole concatenated statement of doctrines contained in the Confession’ but not necessarily to every proposition; (4) that each potential officer must declare any scruple with respect to any article of the confessional standards; (5) that no presbytery may allow the scrupling of any doctrine of the confessional standards but may only allow a scruple at a statement that is not vital to the system of doctrine; and (6) where there are differences of opinion on the significance of the scruple the question is to be determined judicially by the proper ecclesiastical courts, that is, regional Synods and ultimately the General Assembly.
In the past the church abandoned its heritage at two critical junctures. First, the church limited the system of doctrine by Assembly action to just some doctrines. Although the intent of evangelicals within the church was good, the consequence by clear implication declared the other doctrines of the confessional standards no longer to be essential or required of the church officers. Secondly, the church explicitly gave to a presbytery the right to determine which articles of the confessional standards it wanted to consider essential and necessary and the right to determine for itself what the system of doctrine means for the presbytery and those to be ordained.
Let the conservative Presbyterian denominations beware of unwittingly falling into the trap into which some of our evangelical forebears fell when they attempted to define the cardinal doctrines within the Confession in hopes of keeping at least faith in the gospel as requirements for church officers. Furthermore, let the conservative Presbyterian denominations beware lest they permit their General Assemblies to give away to the presbyteries the responsibility which those Assemblies have and thus engender doctrinal disunity.
From a practical perspective, how may the subscription question relative to the second ordination vow be handled safely in the presbyteries? By living before God in dependence upon his wisdom to do courageously that which is right without fear of or favoritism to men.
The decision of the church courts will involve a human being who is asking for admission to the position of officer in the church. He may be a friend, a relative, a son of the church—bright and friendly—perhaps already called by a church that says they desperately need and want just this man. He may be a former student, a former or present parishioner. These and other ties must not blunt the seriousness of the moment and the awesome responsibility of each individual in the court.
The time for the vote comes. If the candidate has indicated that he adopts the confessional standards and its doctrines, or if the candidate scruples or takes exception to the way in which a doctrine is stated but indicates that he agrees with the doctrine, and is in all other ways qualified, let us vote with joy and gladness, welcoming such an individual to take part in the ministry with us.
If, however, the candidate scruples or takes exception to one or more of the doctrines of the system of doctrine of the confessional standards (and not merely to the way the doctrine is stated), let us realize our responsibility before God and to the church in terms of our own solemn ordination vow. Let us remember that the decision we are required to make about this candidate is no different from that which we would make about a potential minister who is a Baptist, or about one who thinks the Ten Commandments are not for the New Testament Church, or about one who has ‘problems’ with predestination or Presbyterian church government. The church has entrusted us with the task of seeing that those admitted to its ministry adopt these confessional standards and the doctrines of the system of doctrine contained within them. Hodge put it well when he said: ‘… it is a breach of faith to God and man if she fails to require a profession of this system by all those whom she receives or ordains as teachers and guides of her people.’ [Discussions in Church Polity, Charles Hodge, p. 340]”
(“Subscription to the Westminster Confession of Faith and Catechisms,” George W. Knight III, The Practice of Confessional Subscription, ed. David Hall, pp. 182-184)

This concern for guarding the church’s doctrinal purity with its peace and unity seems to have come to expression in the Assembly of 1857: 

“The privilege claimed by the Independent ministers, of holding and teaching doctrines not in harmony with the Confession of Faith, is a privilege which, even if harmless in this particular case, might be abused as a precedent, and lead in other quarters and in other relations to serious mischief … in the event that the Independent ministers and churches cannot relinquish their particularities, with a good conscience, this Assembly will cherish them in the bonds of a Christian love but it cannot see its way clear to embrace them in the same denomination.”
(Minutes of the General Assembly of the Presbyterian Church (Old School), 1857, p. 42)

One of the founding members of the PCA has pressed the importance of practical subscription. 

“Church officers are required to submit to the Westminster Standards and to believe that the system of doctrine they contain best reflects in summary form what the Bible teaches. … What has maintained the PCA’s high level of commitment to those Standards has been the agreement that it is not up to the individual officers to determine what is essential to the system, but rather it is a collective judgment made by the church courts to whom the officers are accountable. … Even considering the different levels of commitment and understanding of the Standards, the history of the PCA’s actions reveal the consistency of our doctrinal commitment. The actions of the church courts and the preaching and teaching of the word reflect that confessional commitment.”
(An Inquirer’s Guide to the PCA, Charles H. Dunahoo, pp. 11-12) 

Morton Smith, who was Professor of Systematic and Biblical Theology at Greenville Presbyterian Theological Seminary, wrote, 

“Biblical Basis for Full Subscription
Everything we do as a Church must be based on the Bible, and thus we must consider what the Apostle teaches on the matter before us in a setting in which he sought to fulfill the Great Commission and to guard the Church from all error. In Acts 20 he addressed the Ephesian elders, whom he did not believe he would see again. He recounted his own style of ministry, and then gave a charge to the elders that is still applicable today. It is found in Acts 20:20-28: ‘And how I kept back nothing that was profitable unto you, but have showed you, and have taught you publicly, and from house to house. Testifying both to the Jews, and also to the Greeks, repentance toward God, and faith toward our Lord Jesus Christ … Wherefore I take you to record this day, that I am pure from the blood of all men. For I have not shunned to declare unto you all the counsel of God. Take heed therefore unto yourselves, and to all the flock, over which the Holy Ghost hath made you overseers, to feed the church of God, which he hath purchased with his own blood.’
Note that the preservation of the full and not just a partial Gospel was the concern of the Apostle, for he had just spoken of his personal, special care to teach them the full counsel of God. Later on, Paul addressed the younger minister Timothy thus: ‘Hold fast the form of sound words, which thou hast heard of me, in faith and love which is in Christ Jesus.’ (2 Tim. 1:13) Later he said, ‘And these things that thou hast heard of me among many witnesses, the same commit thou to faithful men, who shall be able to teach others also.’ (2 Tim. 2:2). It is generally agreed that the ‘pattern of sound words’ was some sort of confessional statement of the early Church following the teaching of the Apostle Paul. It is thus our duty to hold fast to the pattern of sound words which we have vowed, containing the system of doctrine taught in Scripture, and thus to pass on the faith once delivered to us to future generations for the continued propagation of the whole counsel of God.
Ultimately Paul teaches that the reason we have for preserving the orthodoxy of the Church of Jesus must stem from our love for Jesus. He purchased the Church with his own blood, making the Church of Christ the most precious and the most important thing on the earth. It is only when we have a real sense of the price that he paid, that we will take seriously the preserving of the whole counsel of God, and the guarding of his Church from all error. In other words, if we love Jesus as we ought, then we should be ready and willing to do all within our power to teach all the counsel of God, and not just a part of it. I believe that full and sincere subscription to our Standards is one of the best means of doing this, because it commits us to the full counsel of God. If we love Jesus, we must do all within our power to preserve and teach that whole counsel to the Church.
The Lesson of History
We are a people who normally value our sense of history; we also think that we should learn the lessons of history, and not commit the same mistakes of our forefathers. The PCA sought to do just this in its separation from its mother Church, the PCUS. We studied the 1936 separation in the North, and we heard the plea of Francis Schaeffer not to make the same mistakes that were made in that separation. …
If we can learn from recent history can we not look back a century and learn from that history as well? It is quite clear that the American Presbyterian Church during the eighteenth century intended the full subscription to the doctrinal Standards. …
Latimer, in his History said, ‘Thanks to the faithful and honest eldership of the Church … From her history … let the Presbyterian Church … learn the important lesson of abiding faithfully by her confession of faith. That confession may, indeed be enlarged, or abridged, or varied, to suit abounding error; but let her … suffer no latitudinarian pretexts of Christian liberty to absolve those who seek to exercise the ministry in her communion from declaring their concurrence in her recognized standards.’”
(“The Case for Full Subscription,” The Practice of Confessional Subscription, pp. 235-239)

Morton Smith provides a window of historical insight that allows us to glean how one experiment in ecumenical cooperation led to doctrinal dilution and was a colossal abject failure for all parties. 

The Old School/New School Conflict
“The Plan of Union of 1801 that was entered into by the Presbyterian Church and the Congregational Churches of Connecticut brought a new development in the area of subscription. First, the Plan allowed for the seating of persons from congregations formed by a merging of Presbyterians and Congregationalists into Congregations, Presbyteries, Synods and General Assembly, without the requirement of subscription. This was contrary to the position of the Presbyterian Church since 1729. One might ask how such an unconstitutional action could be adopted. It was done, no doubt, with every good intention of providing for a peaceable way of joining of two bodies of Christians into one church as they moved west. It was not until the results of the Plan began to be felt, with the establishment of mixed congregations, mixed Presbyteries and mixed Synods that the implications of the action were felt. When the demands were made for subscription, the question of what was involved was raised, and a school of ‘loose’ subscriptionists arose, who argued that all that was being accepted was the system of doctrine, not the Confession and Catechisms themselves as containing that system taught in the Scriptures. This, in effect, nullified the subscription to the Standards, since this ‘system of doctrine’ was thus not defined.
It is not necessary for us to go into all of the history of the conflict between Old and New School Presbyterianism. The conflict came to its climax, when the Old School party took firm control of the Assembly in 1837, and cut off all congregations, presbyteries, and synods that had been formed on the basis of the Plan of Union, without requiring subscription by ministers or elders. All of these bodies were judged to have been formed in an unconstitutional way, and thus not properly deemed a part of the Church. This judgment was not made just on the constitutional point, but also involved a judgment by the Assembly that there was serious doctrinal error within the New School Presbyteries and Synods. Some 16 points of doctrine were condemned by the Assembly.
It has generally been held that the New School Church, with its loose subscription, led to the introduction of liberalism into the Presbyterian Church. Evidence for this may be seen in the next generations of the New School portion of the Church. It was in the Seminaries that allowed the New School view to be taught that liberalism and unbelief were introduced into Presbyterian circles. Princeton Seminary, on the other hand, which was committed to the Old School full subscription position, maintained its orthodoxy until the liberals had gained control of the Assembly and moved to reorganize the Seminary to allow for liberalism to be taught there. This led to the founding of Westminster Seminary in 1929.
In addition to opening the way for the entrance of liberalism into the Presbyterian Church, George Marsden suggests that the New School, as it was at the time of separation in 1837, was more like the modern broad evangelicalism of the twentieth century than modernism.”
(ibid. pp. 245-246) 

“By 1972, the [PCUS] General Assembly raised the question of just how desirable it was to maintaining a theological unity in the church. ‘Meantime the Presbyterian Church in the United States operates with a detailed Confession, the ‘fundamentals’ of which are interpreted with a considerable latitude.’ [Minutes of the Presbyterian Church in the United States, 1972 GA, p. 199]
The reason for reciting this history is to point up the urgency for the PCA to deal with these matters. The drift into liberalism of the Presbyterian Church US came, in part, because of a loose view towards the subscription vow. If the PCA is to remain united, and to remain true to the faith, she needs to say clearly what she expects of her officers when they are called to ‘receive and adopt’ the Confessional Standards of the Church ‘as containing the system of doctrine taught in the Holy Scriptures.’ The intent of the Continuing Church movement was to return to the historic Southern Presbyterian position, which was that of subscription to the Westminster Standards as expressed in the 1861 and 1870 General Assembly deliverances …
The spirit of our subscription is one of submission to the brethren, but even more it is one of submission to the Word of God. This has historically been the spirit expressed in Reformed and Presbyterian confessions. The Scots Confession of 1560 declared in its preface:
‘… if any man will note in our Confession any chapter or sentence contrary to God’s Holy Word, that it would please him of his gentleness and for Christian charity’s sake to inform us of it in writing; and we, upon our honour, do promise him that by God’s grace we shall give him satisfaction from the mouth of God, that is, from Holy Scripture, or else shall alter whatever he can prove to be wrong.’”
(ibid., pp. 251-252, 254) 

“The judicial cases from 1763 to 1810 show a rigid application of the Confession in repression of error. [The great Southern Presbyterian Pastor, Benjamin Morgan] Palmer’s own conclusions on the matter are applicable to every age: ‘It is important, as justifying the measures by which, after a temporary departure, she was reformed back to her original orthodoxy; and because the attempt will be renewed from age to age to escape from the obligation of an extended creed, by an ambiguous subscription of its articles.’ [B.M. Palmer, Life and Letters of James Henley Thornwell (Richmond, VA: 1867), pp. 191-192]
Loose or system subscription was not really advocated until the nineteenth century with the influx of New School Theology into the Presbyterian Church through the Plan of Union with the Congregationalist churches of New England. It was the New School position that one is only required to subscribe to the system of doctrine, and not to the full Confession and Catechisms of the Church. …
To allow loose or system subscription is to open the door for the deformation of the Church. The Southern Presbyterians were not wrong in their judgment of their Northern brethren, when they saw that a union that allowed both views was, in effect, the abandonment of the Old School position, which was based on strict or full subscription. …
The PCA as the Continuing Presbyterian Church was seeking to return to the Old School Presbyterianism of the earlier Southern Church. One must admit that this has not always been recognized, and there is now in the PCA an element of New School thought that is not true to the original intent of the founding fathers of the PCA. Unless the PCA takes efforts to stop the rise of an undefined system subscription within her borders, the future of this Church as an orthodox Church may well be in question also.”
(ibid., pp. 258-259) 

James Urish, pastor of Covenant Presbyterian Church PCA in Lander, Wyoming, observed, 

“Issues in the PCA
The discussion of subscription to the Westminster Standards in the PCA has many of the same issues which have been part of the historical tensions and disagreements in the Presbyterian Church for over two hundred fifty years. Indeed, there are remarkable similarities in the current debates in the PCA to debates held in the Presbyterian Church for the past two centuries. …
It was the formal adopting of the Westminster Confession and Catechisms which formed, as it were, a ‘fence’ around the Presbyterian Church that would define themselves. Those documents of the Westminster Assembly became the theological distinctives of the Presbyterian Church. Since 1729, the Westminster Standards have distinguished the Presbyterian Church on the North American continent from other Christian churches; as well as from other religions and beliefs.
It is hardly fair, then, to allege that the Adopting Act was the point at which the Presbyterian Church broadened. …
Reflections on Subscription
As a confessional church, the PCA has theological and governmental distinctives which are precious. The Constitution of the PCA, consisting of the Westminster Standards, and the Book of Church Order, distinguish her from the rest of Christendom. These documents of the Constitution of the PCA are fallible. Both are able to be modified legally, either by addition or deletion. While the Westminster Standards have rarely been modified, the Book of Church Order is constantly being altered. Yet these documents are to be valued and cherished, while at the same time being recognized as amendable. The Word of God is complete and unamendable. …
It is not without cause for alarm that [Morton] Smith and others warn the PCA about ‘loose subscription.’ Unless the church—particularly its presbyteries—is vigilant, there can be an erosion of our historic Reformed orthodoxy. Candidates coming into the PCA must be carefully scrutinized and thoroughly examined. Even then, with the great care and caution of examining candidates, the church may not screen out all the Hemphills of the 1700s or the Briggs of the 1800s from its midst. In the final analysis, only in heaven will perfect purity, unity, and truth be wholly embraced by the church. Indeed, what seems to be the case over time is that the best and most orthodox of Presbyterian denominations experience theological and governmental entropy.
This ‘fact’ of history is no reason to give up in despair for the PCA. To suggest that there is no hope for the PCA because of the general decline of all churches is an overreaction. Rather, it is important to educate the PCA about its history, and to acquaint our churches and ministers with the people who are the rich legacy of this church. It is only in understanding these men, and the issues for which they fought, that the PCA will be able to avoid the errors of history. It is invaluable to learn of the views of subscription of John Thomson, Jonathan Dickinson, the Tennent family, Archibald Alexander, the Hodges and the heritage of Princeton; as well as the great Southern Presbyterians—Dabney, and Thornwell. This history ought to be broadcast far and wide throughout the PCA, that we might preserve our distinctives as a Presbyterian and Reformed church. …
At the presbytery level, the knowledge of the subscription issue through the years is very helpful. One of the most critical responsibilities of presbytery is examining candidates for the ministry; as well as examining ministers transferring into presbytery. It is extremely important to explore the thinking of candidates who are coming to present themselves to presbytery. …
It is at the presbytery level that the ‘rubber meets the road.’ Presbytery is the first line of defense in preserving orthodoxy of the churches by maintaining the orthodoxy of its ministers. When presbyteries let down their guard concerning this responsibility, the PCA distinctives will erode. … In training officers for serving as elders or deacons, it is important to tighten down the form and freedom to strict subscription. Officers in PCA churches are required to affirm the same second ordination vow as ministers. Sessions must, then, ‘sincerely receive and adopt the Confession of Faith and the Catechisms of this church, as containing the system of doctrine taught in the Holy Scriptures.’”
(“A Peaceable Plea About Subscription: Toward Avoiding Future Divisions,” James E. Urish, The Practice of Confessional Subscription, ed. David Hall, pp. 290-296)

Francis Schaeffer, an American evangelical theologian, philosopher, and Presbyterian pastor, in his chapter “A Christian View of the Church: The Church Before the Watching World,” discussed “… a growing latitudinarianism; this has tended to happen in evangelical circles in the United States. The tendency is to go from ecclesiastical latitudinarianism to cooperative comprehensiveness. …
If one stays in a denomination that is completely dominated by liberals and he gives in to the ecclesiastical latitudinarianism which becomes a cooperative comprehensiveness, there is a tendency to drift into doctrinal comprehensiveness and especially to let down on a clear view of Scripture.” (Complete Works, pp. 159-160) That was obviously decades ago, he wasn’t referring specifically to the PCA, and it’s not necessary to quote Schaeffer at length, yet his warning about “ecclesiastical latitudinarianism” seems apposite to the discussion of how the PCA’s permission of its officers to work in non-PCA churches might derogate the denomination’s doctrinal fidelity. 

The questions of what types of ecclesiastical cooperation with non-Presbyterian churches are appropriate for our denomination, and the latitudinarianism that can cause vicious, intractable entanglements with incompatible polities, evidently are not new ones. This simple Church member approaches these issues with several years of experience observing and living the asperities that such latitudinarian compromises can trickle down in a church. In light of what we read from our sage Presbyterian forebearers such as the Bannermans, they faced issues that are basically similar and emerged on the other side with wisdom and advice that they have bequeathed to us moderns. 

Dr. Taylor has written, 

“The subscription issue is not simply a matter for discussion and controversy among elders, pastors, theologians, and seminarians; it is a matter of great consequence in the life of the Church. There are practical implications of this theological discussion just as with other doctrinal matters. … There is a tendency to shy away from controversy in the interests of peace. However, theology is developed and honed through controversy. The first General Assembly of the apostolic Church, the so-called Jerusalem Council of Acts 15, was occasioned by the controversy surrounding the relationship of the ceremonial law to the rapidly growing cadre of Gentile converts. No doubt the dispute carried a certain degree of trauma to the Christians involved. Nevertheless, there were indisputable benefits to the Church in that the Gentile influx into the Church continued and accelerated while there was some deference shown to the Jewish base of the Church. Though some might wish the subscription controversy would simply go away, it is good to remember that this controversy is not new in Reformed circles … We should recognize that dealing with subscription can have positive benefits. …
Reformed Churches are confessional churches. The basis of our unity is a unity of the faith, a unity based on common commitment to biblical truths. Ours is not a unity of uniform liturgy, nor a unity based on a cooperative program of ministry, but a unity of truth out of which flows our worship and ministry. … We have a confession of faith of biblical truths to which we are committed, which forms part of our constitution, binding all ordained office-bearers. It is no accident of history that the Westminster Standards are regarded as the apex of Protestant theological confessions, the most extensive confession to result from the Reformation. We do not have a short list of essential doctrines but an integrated system of theology expressed in our standards. We do not regard the Westminster Standards merely as interesting historical documents by which we will be guided and informed. We subscribe to the Westminster Standards as containing the system of doctrine taught in Holy Scripture. It is because we love the God of truth that we study the truth of God. Taking our ordination vows as a solemn oath before God, rather than as a perfunctory act, requires us to examine the Scriptures (Acts 17:11) as the Berean Christians did. An honest understanding of subscription to the Westminster Standards will motivate and compel all office-bearers to study the Scriptures and to think theologically. Such thinking should result in our living out the implications of the Reformed Faith in the life and ministry of our churches.”
(“Practical Benefits and Dangers of Subscription,” L. Roy Taylor, The Practice of Confessional Subscription, ed. David Hall, pp. 393-396)

Joel Beeke, although not Presbyterian in the Scottish tradition, lends insight as a Dutch Reformed, which is essentially presbyterian. He looks to the example of Ezra, whose scribal order, sofer, is accepted by many scholars as the ecclesiological lineage of the modern presbyterial teaching elder. 

“As the servants of the Lord Christ, we dare not govern the church according to our opinions or the teachings of mere men. We must hammer out our decisions on the anvil of the Word of God and fire them with fervent prayers. When faced with a question, we must ask, ‘What doctrines, laws, sayings, events, and examples in the Bible are relevant to this matter? What has God said about it?’ We must focus our eyes upon the goal of doing God’s will—not maintaining our personal comfort, keeping our people happy, or attracting the largest number of people. Ezra is our model of true ministerial success: ‘the good hand of his God’ was ‘upon him,’ for he ‘had prepared his heart to seek the law of the LORD, and to do it, and to teach in Israel statutes and judgments’ (Ezra 7:9-10). …
Our priority must be informing the mind for training in godliness. The goal of the ministry is love, a good conscience, and a sincere faith (1 Tim. 1:5). We reprove lawless acts that are ‘contrary to sound doctrine’ (v. 10). We teach the ‘sound words’ of biblical truth so that people might cling to them ‘by the Holy Ghost which dwelleth in us’ (2 Tim. 1:13-14). … Whether we teach the catechism to children or systematic theology to graduate students, we must foster a merging of truth and godliness, Word and Spirit. This holy blend begins with the humility of the teacher. Do not present yourself as a master of the Word, but as one who longs to be mastered by the Word. …
Everyone who aspires to be a teacher of the Word should remember the warning posted by James: ‘My brethren, be not many masters, knowing that we shall receive the greater condemnation. For in many things we offend all’ (James 3:1, 2).”
(Reformed Systematic Theology Vo1. 1, Joel Beeke & Paul Smalley, pp. 472-473) 

Another important consideration is that Scripture and The Book of Church Order delineate our jure divino governance as the very instrumentality by which the Church is to evangelize the world. sets forth the Church’s vision: “The Presbyterian Church in America (PCA) was formed in 1973 to be a denomination that is ‘Faithful to the Scriptures, True to the Reformed Faith, and Obedient to the Great Commission,’” and, “As one communion in the worldwide church, the Presbyterian Church in America exists to glorify God by extending the kingdom of Jesus Christ over all individual lives through all areas of society and in all nations and cultures.”

Part I: Form of Government
Chapter 3: The Nature and Extent of Church Power
3-3. The sole functions of the Church, as a kingdom and government distinct from the civil commonwealth, are to proclaim, to administer, and to enforce the law of Christ revealed in the Scriptures.
3-5. The Church, with its ordinances, officers and courts, is the agency which Christ has ordained for the edification and government of His people, for the propagation of the faith, and for the evangelization of the world.
3-6. The exercise of ecclesiastical power, whether joint or several, has the divine sanction when in conformity with the statutes enacted by Christ, the Lawgiver, and when put forth by courts or by officers appointed thereunto in His Word. 

Morton Smith wrote, 

Commentary on The Book of Church Order of the Presbyterian Church in America
Comment on BCO 3-5, p. 39
“This seems to be an obvious statement of fact. It is one, however, that has often been neglected in American Church history. The use of independent agencies to carry out functions particularly delegated to the Church is a commonplace practice in America today. It arises from a low view of the Church, which in turn has arisen from the failure to preserve the purity of the Church through due exercise of discipline. When the Church is allowed to drift from its proper functions, then the people of God feel it proper to turn elsewhere to carry out the Great Commission of Christ. If the Church, on the other hand, is what she ought to be, and does what she is commanded by Christ her Lord to do, then there is no call for non-Biblical structures to try to replace her.” 

With this comment, our first Stated Clerk most likely referred to how the PCA collaborates with the parachurch. Discussing the legitimacy of parachurch organizations is beyond the scope of this interaction; what we’re chiefly concerned with here is the precarious nature of our Presbyterian ministers not ruling jointly in our system of Church courts, yet ruling in ecclesiastical settings where there are human beings under authority, and direct discipleship and discipline take place. 

The Great Commission is a tall order. Scripture promises that God grants Spiritual power to those who are punctilious with the directives he already has issued (Deuteronomy 28, Proverbs 3:3-4, Matthew 25:23, Luke 12:42-44, 16:10-12, 19:12-25, John 14:15, I Peter 4:17). Calvin wrote, 

“Let not a contemptuous idea of our insignificance dissuade you from the investigation of this cause. … But our doctrine must stand sublime above all the glory of the world, and invincible by all its power, because it is not ours, but that of the living God and his Anointed, whom the Father has appointed King, that he may rule from sea to sea, and from the rivers even to the ends of the earth.”
(Institutes, “Prefatory Address by John Calvin to Francis I, King of France,” 1536) 

Alluding to Psalm 72:8, Calvin was referring to the glorious fulfillment of the Great Commission. The task before us in evangelism would be a lost cause without the Holy Spirit’s superintendence, and Calvin elsewhere pressed the internal integrity of the Church without which she is impotent: 

“God, therefore, sets up his kingdom, by humbling the whole world, though in different ways, taming the wantonness of some, and breaking the ungovernable pride of others. We should desire this to be done every day, in order that God may gather churches to himself from all quarters of the world, may extend and increase their numbers, enrich them with his gifts, establish due order among them; on the other hand, beat down all the enemies of pure doctrine and religion, dissipate their counsels, defeat their attempts. Hence it appears that there is good ground for the precept which enjoins daily progress, for human affairs are never so prosperous as when the impurities of vice are purged away, and integrity flourishes in full vigor. The completion, however, is deferred to the final advent of Christ, when, as Paul declares, ‘God will be all in all’ (1 Cor 15:28). This prayer, therefore, ought to withdraw us from the corruptions of the world which separate us from God, and prevent his kingdom from flourishing within us.”
(Institutes 3.20.42) 

The practice of lending out our teaching elders to ecclesiastical settings which do not follow PCA rules presents perils which can vitiate our effectiveness to govern and shepherd our own officers and, counterintuitively to the cooperativism that may be intended by such clerical liaisons, actually undermine our evangelistic progress as a Church. Without proceeding with tremendous caution when approving any out-of-bounds calls especially in non-PCA churches, our presbyteries risk teaching elders using the out-of-bounds privilege basically as a wild card to operate in diluted accountability and ignore with impunity the rules of the BCO which all other teaching elders at PCA churches, who are beholden to the PCA for their credentials, have to follow. In the process of allowing our pastors to operate in unchecked environments, our denomination also risks devaluing our officers’ credentials, tacitly communicating that our Presbyterian principles may be negotiable. 

One avowed subscriber to the Westminster Confession of Faith, a PCA teaching elder, has written, 

“Since our entire relationship to God is based upon covenant promises, God sanctifies the matter of vows, oaths, and promises. Trust in human relationships (such as marriage and business agreements) is necessary for the welfare of society. A lawful oath is a part of worship wherein people, seeking to assure the veracity of what they speak, call upon God as a witness of what they assert and promise. The implication is that if those taking oaths are found to be lying, God will punish them with swiftness and severity.
The Christian church has always affirmed the value of oaths and vows. The Westminster divines listed the following scriptural boundaries and stipulations,
The name of God only is that by which men ought to swear, and therein it is to be used with all holy fear and reverence. Therefore, to swear vainly or rashly, by that glorious and dreadful Name, or, to swear at all by any other thing, is sinful, and to be abhorred. Yet, as in matters of weight and moment, an oath is warranted by the Word of God, under the New Testament as well as under the Old; so a lawful oath, being imposed by lawful authority, in such matters, ought to be taken.”
(Essential Truths of the Christian Faith, Chapter 85, Oaths and Vows, R.C. Sproul, pp. 241-242) 

The responsibility of Church courts to preserve the Confessional Subscription among all PCA ministers seems to favor a more economical employment of the PCA’s out-of-bounds provision than some presbyteries sometimes have taken liberty, especially in respect to irregular calls where ecclesiastical duties saddle ministers with principles incongruous to the Presbyterian vows which are their primary allegiance. Consider that when American Presbyterians adopted the Westminster Confession of Faith in 1729 for the Church constitution, and men who sought ordination could request exceptions, those were known as scruples. The PCA’s Confessional Subscription is mostly unchanged from our Presbyterian heritage of the past three centuries. Were our own ministers to routinely labor in conflict with this subscription, especially with methods that are hostile to our system of governance or strike at the vitals of religion, it would epitomize the word unscrupulous

Thus, if a presbytery’s approval of a TE’s out-of-bounds call to a non-PCA church was found to be unconstitutional, then such a ruling consequently must be indiscreet, discreditable and haphazard. 

When Presbyterian pastors run churches out of ecclesiastical bounds, who oversees the overseers? 

If their church records are not discoverable, how can we know they practice what they preach?

Without a Confessional Subscription that presbyteries are able to enforce, the Church is bereft of practical means to ensure our pastors faithfully rule coram populo: before the public; coram ecclesia: before the assembly; coram presbyteris: before presbytery; and above all, coram Deo: before God. 


The points set forth in this treatise are integral to a broader systematic view of Reformed and Presbyterian ecclesiology. For important further study, refer to the Fundamentals of Presbyterianism 2020 article series, which then became Appendix VI in the September 18, 2020 Complaint of Peter Benyola versus the Central Florida Presbytery (cf. SJC 2020-13): 
Why ecclesiology is important for Christians, Fundamentals of Presbyterianism, part 1
God’s apostolic model for elders in graded church courts, Fundamentals of Presbyterianism, part 2
God’s decree of congregational right to elect church officers, Fundamentals of Presbyterianism, part 3
God’s design for orderly discipline in graded church courts, Fundamentals of Presbyterianism, part 4
The folly of corrupt clergy who rape Christ’s bride of her electoral rights, Fundamentals of Presbyterianism, part 5

The divine command for an unpresbyterated church to submit to the Presbyterian courts (originally Appendix III in the Complaint of Peter Benyola versus the Central Florida Presbytery)
The pernicious erosion of ‘prelatic developments’ upon Presbyterian parity, plurality (originally Appendix II in the Complaint of Peter Benyola versus the Central Florida Presbytery)

ecclesiology, polity, Presbyterianism