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PeerBasis
Compensation Comparability Determination

Pennsylvania Sons And Daughters Of Italy

Executive Director / CEO

EIN 237535672
PA · NTEE Y40
FY ending 2024-12-31
June 9, 2026

This analysis benchmarks the total compensation of Tracey Williams, Executive Director / CEO ($11,007) against every comparable organization that fit the selection criteria — 38 in total — drawn systematically from IRS Form 990 filings, not a hand-picked subset.

Compensation sits at approximately the 66th percentile of comparable organizationswithin the typical range

Benchmarked executive: Tracey Williams — reported title “Bar-tender”, selected as the organization's highest-paid individual — no exact title match, so confirm this is a comparable role.

How comparable organizations were selected

38 organizations qualified on sector, size, and geography 38 within the band form the benchmarked peer set.

Distribution of comparable compensation

$962 total compensation of comparable organizations → $30,928 $11,007
$1,88610th
$3,19925th
$6,051Median
$15,08275th
$22,79990th
$11,007This org · 66th
p10$1,886
p25$3,199
p50$6,051
p75$15,082
p90$22,799
$11,007

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.

OrganizationStateRevenueMatched titleComp
(reported)
Comp
(adjusted)
FY
Fraternal Order Of Eagles Aerie 4336 MO$184,174 Bartender $11,110 $11,496 2025
Coventry-west Greenwich Lodge #2285 Of The Bpoe RI$196,664 Secretary $4,100 $3,840 2025
Wayne D Clark Aerie 4488 VA$199,060 Worthy Presi $25,460 $24,651 2024
Benevolent And Protective Order Of Elks FL$200,491 1 Year Trustee $14,625 $13,422 2025
Loyal Order Of The Moose 1560 TN$175,498 Administrator $28,000 $28,752 2025
Fraternal Order Of Eagles CA$202,792 Secretary $5,542 $4,675 2025
Cloquet Lodge 1274 Loyal Order Of Moose MN$204,882 Administrator $10,400 $10,305 2024
Fraternal Order Of Eagles VT$205,841 Secretary Tr $11,110 $11,214 2024
Chico-leland Stanford Masonic Temple Association CA$210,124 Cfo $21,308 $18,451 2024
Montana State Elks Association Llc MT$165,106 Treasurer $2,000 $2,106 2025
Fraternal Order Of Eagles 1502 WI$161,760 Secretary $1,836 $1,923 2024
Benevolent & Protective Order Of AL$161,081 Treasurer $5,200 $5,488 2025
Scott County Moose Lodge No 2324 IN$216,053 Administrator $10,200 $10,508 2025
Benevolent & Protective Order Of Elks Of The Usa NY$217,775 Secretary $1,500 $1,324 2025
Benv & Protective Order Of Elks 310 ID$157,838 Secretary $9,500 $9,873 2025
Masonic Charities Of Maryland Inc MD$152,882 Grand Secretary $9,099 $8,783 2023
Cambridge Lodge No 1211 Loyal Order Of Moose MD$225,271 Administrator $17,225 $15,732 2025
Fraternal Order Of Eagles Aerie4300 OH$228,881 President $1,200 $1,242 2025
Shelby Owls Club Nest 2553 Inc OH$145,274 Secretary/tr $29,120 $30,928 2024
Benevolent & Protective Order Of OR$232,947 Secretary $17,234 $15,635 2025
Sierra Vista Lodge No 2065 AZ$141,677 Secretary $6,000 $5,637 2025
Sons Of Italy PA$141,177 President $1,800 $1,800 2024
Fraternal Order Of Eagles Aerie 67 UT$236,916 Secretary $2,723 $2,723 2025
Brockport Lodge No 2110 Benevolent NY$238,390 Secretary $5,900 $5,346 2024
Bpoe Elks Palmetto Lodge 2449 FL$137,282 Secretary $3,218 $3,031 2024

Comp (reported) is the figure on each organization's Form 990 (columns D + F); Comp (adjusted) normalizes it to PA 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 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.

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 default66th
Total compensation (D + F), as reported (no adjustments)66th
Reportable pay only (column D), adjusted66th
All sources (D + E + F), adjusted63rd

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 (Tracey Williams) 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 38 similarly situated organizations (Same NTEE sector (Y40), nationwide + budget 0.67–1.5× revenue).
  3. The authorized body determined that total compensation of $11,007 is reasonable (approximately the 66th 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.