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PeerBasis
Compensation Comparability Determination

Westminster Afc Inc

Executive Director / CEO

EIN 205445903
CO · NTEE B99
FY ending 2023-12-31
June 9, 2026

This analysis benchmarks the total compensation of Paul Mulvany, Executive Director / CEO ($15,231) against every comparable organization that fit the selection criteria — 426 in total — drawn systematically from IRS Form 990 filings, not a hand-picked subset.

Compensation sits at approximately the 11th percentile of comparable organizationsbelow the typical range for comparable organizations

How comparable organizations were selected

426 organizations qualified on sector, size, and geography 426 within the band form the benchmarked peer set.

Distribution of comparable compensation

$128 total compensation of comparable organizations → $287,628 $15,231
$14,77010th
$34,48925th
$53,897Median
$78,21275th
$106,93090th
$15,231This org · 11th
p10$14,770
p25$34,489
p50$53,897
p75$78,212
p90$106,930
$15,231

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 CO cost of living (BEA RPP, 2023) and to its filing year (CPI-U); the reported amount is on each linked 990.

OrganizationStateTotal revenueTotal compSource
Gods' Warriors IncGA $297,298$73,333 990
Educare Central MaineME $296,987$29,908 990
Capacity CatalystTX $298,161$42,380 990
Harpswell Neck Fire & Rescue IncME $296,538$6,086 990
Justice And Soul FoundationWA $298,489$32,680 990
Bad Girl Ventures IncKY $296,082$118,841 990
Harbaugh Coaching Academy IncMD $298,889$24,355 990
Game Meets Game IncMD $295,966$55,167 990
National Association OfDC $295,686$6,068 990
Lowcountry Maritime SchoolSC $299,340$66,316 990
Impact Bay AreaCA $294,978$54,392 990
Equalai Charitable FoundationDC $300,000$18,806 990
Project DivaMN $300,416$78,492 990
Marshallese American Network For Interacting TogetherOR $300,457$63,779 990
262 Foundation IncMA $300,469$38,231 990
Fletcher Park Baptist Youth Foundation IncWY $294,388$54,510 990
C2e IncorporatedGA $300,619$6,693 990
Eastern Educational ResourceOR $301,148$100,722 990
Red Salmon ArtsTX $293,557$63,533 990
Pegasus Media ProjectTX $301,363$55,259 990
Ulster Literacy Association IncNY $293,107$61,785 990
Mapping Your FutureTX $293,043$105,656 990
Cincinnati Interfaith Workers CenteOH $302,833$81,068 990
Being Built TogetherCA $302,850$57,463 990
Womens Center For Economic OpportunityOH $291,671$48,877 990

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 CO 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 default11th
Total compensation (D + F), as reported (no adjustments)10th
Reportable pay only (column D), adjusted16th
All sources (D + E + F), adjusted10th

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 (Paul Mulvany) 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 426 similarly situated organizations (Same NTEE sector (B99), nationwide + budget 0.67–1.5× revenue).
  3. The authorized body determined that total compensation of $15,231 is reasonable (approximately the 11th 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). 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.