Executive Director / CEO
This analysis benchmarks the total compensation of Joanna Otero-cruz, Executive Director / CEO ($12,685) against every comparable organization that fit the selection criteria — 90 in total — drawn systematically from IRS Form 990 filings, not a hand-picked subset.
Compensation sits at approximately the 0th percentile of comparable organizationsbelow the typical range for 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 PA cost of living (BEA RPP, 2023) and to its filing year (CPI-U); the reported amount is on each linked 990.
| Organization | State | Total revenue | Total comp | Source |
|---|---|---|---|---|
| Equal Access Legal Services Inc | PA | $353,409 | $88,365 | 990 |
| Southwest Georgia Legal Self-help | GA | $342,337 | $32,497 | 990 |
| Legal Resource Center On Violence Against Women Inc | MD | $340,335 | $104,345 | 990 |
| Greater Dayton Volunteer Lawyers Project | OH | $339,911 | $89,751 | 990 |
| Self Help Inc | NM | $358,462 | $65,058 | 990 |
| World Immigration Center Inc | NY | $335,018 | $47,119 | 990 |
| Pro Bono Organization For Native | HI | $362,223 | $69,763 | 990 |
| Atlantic Area Court Appointed Casa | GA | $333,808 | $74,446 | 990 |
| Monroe County Senior Legal Services | MI | $363,058 | $70,257 | 990 |
| Childrens Advocacy Center Of West Texas Inc | TX | $363,194 | $64,750 | 990 |
| National Veterans Benefits Attorneys Inc | FL | $365,619 | $45,924 | 990 |
| Iron Defense | MI | $367,750 | $107,139 | 990 |
| Trinity Legal Clinic Of Oklahoma | OK | $326,987 | $60,432 | 990 |
| Financial Protection Law Center | NC | $370,385 | $126,612 | 990 |
| Emergency Legal Responders | LA | $317,714 | $88,473 | 990 |
| The Joseph Project Inc | MI | $314,352 | $31,051 | 990 |
| Student Legal Services Inc | NY | $312,839 | $81,377 | 990 |
| Arizona Justice For Our Neighbors | AZ | $312,535 | $89,317 | 990 |
| The Association Of The Federal Bar Of The State Of New Jersey | NJ | $384,805 | $54,815 | 990 |
| Legal Works Inc | OH | $385,248 | $99,837 | 990 |
| Servicios Legales Comunitarios Inc | PR | $309,343 | $66,196 | 990 |
| Oklahoma Access To Justice Foundation | OK | $387,073 | $84,588 | 990 |
| Court Appointed Special Advocates | TX | $387,568 | $65,149 | 990 |
| Connect Immigration | CO | $306,327 | $81,254 | 990 |
| Neighborhood Legal Support Of Kansas City | MO | $390,055 | $101,201 | 990 |
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 PA 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.
Sensitivity — the subject's percentile under alternative compensation definitions:
| Basis | Subject percentile |
|---|---|
| Total compensation (D + F), cost-of-living + inflation adjusted — the PeerBasis default | 0th |
| Total compensation (D + F), as reported (no adjustments) | 0th |
| Reportable pay only (column D), adjusted | 0th |
| All sources (D + E + F), adjusted | 99th |
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.
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
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.