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PeerBasis
Compensation Comparability Determination

Sir Harold Acton Charitable Trust

Executive Director / CEO

EIN 137050560
NY · NTEE B110
FY ending 2024-12-31
June 9, 2026

This analysis benchmarks the total compensation of Linda Mills, Executive Director / CEO ($852,245) against every comparable organization that fit the selection criteria — 16 in total — drawn systematically from IRS Form 990 filings, not a hand-picked subset.

Compensation sits at approximately the 100th percentile of comparable organizationsabove the 90th percentile — board review recommended

Benchmarked executive: Linda Mills — reported title “CO-TRUSTEE”, selected as the organization's highest-paid individual — no exact title match, so confirm this is a comparable role.

How comparable organizations were selected

16 organizations qualified on sector, size, and geography 16 within the band form the benchmarked peer set.

Distribution of comparable compensation

$18,413 total compensation of comparable organizations → $302,063 $852,245
$27,68010th
$42,35525th
$80,186Median
$167,70475th
$184,28190th
$852,245This org · 100th
p10$27,680
p25$42,355
p50$80,186
p75$167,704
p90$184,281
$852,245

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 NY 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
Suny Maritime Foundation Inc NY$2,798,926 Executive Dir. $36,036 $36,036 2024
Yeshiva Endowment Foundation Inc NY$2,702,741 President-director $164,942 $169,814 2023
Ubuntu Pathways Inc NY$2,608,914 Ceo & Founder $293,397 $302,063 2023
Nysernetnet Inc NY$3,102,946 Director $54,743 $54,743 2024
Onondaga Community College NY$3,163,652 Secretary $18,413 $18,413 2024
🔒 11 more comparable organizations — included in the purchased report

Comp (reported) is the figure on each organization's Form 990 (columns D + F); Comp (adjusted) normalizes it to NY 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 NY 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 default100th
Total compensation (D + F), as reported (no adjustments)100th
Reportable pay only (column D), adjusted0th
All sources (D + E + F), adjusted100th

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:

Ready-to-adopt board minutes — executive compensation

🔒 The complete minutes language — three numbered resolutions pre-filled with this organization, the 16-organization comparison, the date, and the percentile finding, ready to paste into your minutes — is included in the purchased report.

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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.