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PeerBasis
Compensation Comparability Determination

Beautiful Downtown Lewiston

Executive Director / CEO

EIN 262200307
ID · NTEE S32
FY ending 2022-12-31
June 9, 2026

This analysis benchmarks the total compensation of Brenda Morgan, Executive Director / CEO ($72,120) against every comparable organization that fit the selection criteria — 17 in total — drawn systematically from IRS Form 990 filings, not a hand-picked subset.

Compensation sits at approximately the 76th percentile of comparable organizationswithin the typical range

Benchmarked executive: Brenda Morgan — reported title “Executive Dir.”, a direct title match to the Executive Director / CEO role.

How comparable organizations were selected

17 organizations qualified on sector, size, and geography 17 within the band form the benchmarked peer set.

Distribution of comparable compensation

$18 total compensation of comparable organizations → $123,844 $72,120
$2,21310th
$15,85125th
$43,675Median
$67,84375th
$94,22890th
$72,120This org · 76th
p10$2,213
p25$15,851
p50$43,675
p75$67,843
p90$94,228
$72,120

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 ID 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
Cadco Foundation Inc WV$239,336 President And Ceo From 10/01/24 $19 $18 2024
Rural Development Leadership NY$206,538 President $20,000 $15,851 2024
Greencastleputnam Co Developmt Cntr Inc IN$203,626 Executive Director $93,000 $86,021 2024
West End Economic Development Corporation CO$200,738 Executive Director $71,536 $61,942 2023
Harrison County Agriculture Society IA$191,314 Manager $3,600 $3,457 2024
Driftless Development Inc WI$186,492 Executive Director $73,550 $67,373 2024
Rural Services Of Indiana Inc IN$267,542 Director $130,050 $123,844 2023
Yadkin County Economic Development NC$273,413 President $101,010 $91,544 2024
Center For Community Transformation Inc OK$277,565 Secretary-treasurer $4,257 $4,111 2024
Rural Preservation Company Of Clinton NY$278,985 Executive Dir. $55,105 $43,675 2024
Valdese Economic Development Invest NC$288,431 Director $72,711 $67,843 2023
Rei Capital Access Fund Inc OK$292,647 President $42,667 $41,209 2024
Griggs-steele Empowerment Zone Inc ND$296,295 President $360 $347 2024
The Living River Restoration Trust VA$311,836 Executive Director $29,231 $24,755 2024
Logan County Economic Development CO$320,715 Executive Director $113,473 $98,254 2023
The Granary Foundation NE$329,446 Executive Director $17,257 $16,280 2024
Southernmost Illinois Delta Empowerment Zone Inc IL$332,466 Executive Director $63,591 $54,834 2024

Comp (reported) is the figure on each organization's Form 990 (columns D + F); Comp (adjusted) normalizes it to ID cost of living and 2022 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 ID 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 default76th
Total compensation (D + F), as reported (no adjustments)65th
Reportable pay only (column D), adjusted76th
All sources (D + E + F), adjusted65th

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 (Brenda Morgan) 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 17 similarly situated organizations (Same NTEE sector (S32), nationwide + budget 0.67–1.5× revenue).
  3. The authorized body determined that total compensation of $72,120 is reasonable (approximately the 76th 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.