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PeerBasis
Compensation Comparability Determination

American Legion Post 204 Harold N Keith

Executive Director / CEO

EIN 046166379
MA · NTEE W30Z
FY ending 2024-08-31
June 9, 2026

This analysis benchmarks the total compensation of Richard Freeman, Executive Director / CEO ($7,200) against every comparable organization that fit the selection criteria — 74 in total — drawn systematically from IRS Form 990 filings, not a hand-picked subset.

Compensation sits at approximately the 23rd percentile of comparable organizationsbelow the typical range for comparable organizations

Benchmarked executive: Richard Freeman — reported title “FINANCE OFFICER”, selected as the organization's highest-paid individual — no exact title match, so confirm this is a comparable role.

How comparable organizations were selected

74 organizations qualified on sector, size, and geography 74 within the band form the benchmarked peer set.

Distribution of comparable compensation

$57 total compensation of comparable organizations → $670,532 $7,200
$2,04910th
$10,27625th
$28,643Median
$51,10475th
$68,36590th
$7,200This org · 23rd
p10$2,049
p25$10,276
p50$28,643
p75$51,104
p90$68,365
$7,200

Comparable organizations

Each figure is Form 990 Part VII columns D + F (reportable pay plus other compensation and benefits; column F may include amounts from related organizations), normalized to MA cost of living (BEA RPP, 2023) and to its filing year (CPI-U); the reported amount is on each linked 990.

OrganizationStateRevenueMatched titleComp
(reported)
Comp
(adjusted)
FY
North Shore Veterans Counseling MA$197,898 Executive Di $53,000 $53,000 2024
Vietnam Veterans Of America #317 MO$195,555 President $34,182 $39,250 2025
Veterans Of Foreign Wars Of The United CA$199,976 Treasurer $42,000 $40,359 2024
Lafayette War Veterans CA$201,261 Center Director $96,658 $95,624 2023
American Veterans Service Dog IL$201,691 Treasurer - $28,800 $32,439 2023
Walter Jones Post 2876 Veterans Of IL$191,118 Jr Vice Comm $10,830 $11,848 2024
Pymatuning Veterans Home Assn PA$202,671 President $10,400 $11,541 2024
Hevin WA$203,834 Vice-presden $25,750 $25,655 2024
Watsontown American Legion Club Inc PA$189,157 Finance Officer $4,050 $4,494 2024
Pin-ups For Vets CA$188,710 President $107,529 $103,327 2024
American Legion Morris Snuggerud Post Membership WI$207,094 3rd Vice Commandergm $51,688 $60,071 2024
Dtom 220 Foundation SD$207,188 Ceo, Chairman Of The Board $36,040 $45,570 2023
Peoples Foundation For Connecting Community Military & Veterans CA$207,511 Secretary $1,500 $1,484 2023
American Patriot Service Corporatio UT$184,349 President $11,999 $13,666 2024
American Legion Post 0094 Charles Pratt Post IN$182,068 Bar Gaming Manager $38,055 $43,508 2025
Veterans Of Foreign Wars 9566vfw-mass MA$180,705 Past Quartermaster $4,410 $4,410 2024
Whitehall Lodge No 1491 Bpoe NY$180,612 Secretary $1,500 $1,469 2025
Veterans Of Foreign Wars Of The United States Dept Of Florida FL$179,435 Quartermaster $2,600 $2,648 2025
Veterans Of Foreign Wars CA$216,406 Commander $2,020 $1,941 2024
Veterans Of Foreign Wars Department Of AK$176,865 Quartermaster $5,990 $6,561 2023
Us Army Warrant Officers Association VA$173,506 Executive Director/ Editor $62,398 $67,045 2024
Veterans Of Foreign Wars Post 614 NM$221,500 Commander $12,301 $14,344 2025
Hero Expeditions Incorporated CO$170,678 Executive Director $36,000 $38,414 2024
U S Veterans Post 104 Corporation FL$170,207 Quartermaster $2,000 $2,153 2023
Veterans Education Project VA$170,000 Executive Director $30,000 $32,234 2024

Comp (reported) is the figure on each organization's Form 990 (columns D + F); Comp (adjusted) normalizes it to MA cost of living and 2024 dollars. Click any organization to verify the figure on ProPublica.

Methodology

Comparable organizations were drawn from electronically filed IRS Form 990 returns and matched on sector (NTEE code), budget (a size-adaptive revenue band that tightens as the organization grows), and geography (same-state first, broadening only when too few peers qualify); every organization within the band forms the peer set. To compare fairly across regions and years, peer compensation is normalized to MA cost of living (BEA Regional Price Parities, 2023) and to the subject's filing year (CPI-U). The figure benchmarked is Form 990 Part VII, Section A, columns D + F — reportable pay plus other compensation, benefits, and deferred amounts (column F may include amounts from related organizations) — with the chief executive matched by role. Related-organization amounts (column E) and institutional trustees are excluded. Full methodology: peerbasis.org/methodology.

Sample, role match & sensitivity

Sensitivity — the subject's percentile under alternative compensation definitions:

BasisSubject percentile
Total compensation (D + F), cost-of-living + inflation adjusted — the PeerBasis default23rd
Total compensation (D + F), as reported (no adjustments)24th
Reportable pay only (column D), adjusted26th
All sources (D + E + F), adjusted20th

If the percentile moves materially across these definitions, the result is sensitive to methodology choices, and the board should weigh which basis best fits its facts.

Rebuttable presumption of reasonableness · 26 CFR 53.4958-6

Compensation paid by a tax-exempt organization is presumed reasonable — shifting the burden to the IRS — when three requirements are met. This report supplies the comparability data for the second. The board should record the following in its minutes concurrently with its decision:

Draft board minutes — executive compensation

  1. The compensation of the Executive Director / CEO (Richard Freeman) was approved in advance by [the Board / Compensation Committee], composed of members with no conflict of interest with respect to the arrangement.
  2. Prior to its determination, the authorized body obtained and relied upon appropriate comparability data, namely the PeerBasis Compensation Comparability Determination dated June 9, 2026, comparing compensation against 74 similarly situated organizations (Same NTEE sector (W30), nationwide + budget 0.67–1.5× revenue).
  3. The authorized body determined that total compensation of $7,200 is reasonable (approximately the 23rd percentile of comparable organizations) and documented the basis for this determination concurrently, on [date], by a vote of [__ for / __ against].

Sources: IRS Form 990 e-file data (apps.irs.gov); IRS Business Master File (NTEE classification). Every figure traces to an original public filing — click any organization above to verify it on ProPublica. PeerBasis is a service of Prismind Analytics; its methodology is published, was commissioned for independent adversarial review, and discloses its own limitations. This report is comparability data to support a board's good-faith determination under IRC 4958; it is not legal or tax advice. Generated by PeerBasis on June 9, 2026.