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PeerBasis
Compensation Comparability Determination

Elks National Foundation Inc

Executive Director / CEO

EIN 263718342
IL · NTEE T31
FY ending 2025-03-31
June 9, 2026

This analysis benchmarks the total compensation of James O'kelley Iii, Executive Director / CEO ($176,371) against every comparable organization that fit the selection criteria — 32 in total — drawn systematically from IRS Form 990 filings, not a hand-picked subset.

Compensation sits at approximately the 6th percentile of comparable organizationsbelow the typical range for comparable organizations

How comparable organizations were selected

32 organizations qualified on sector, size, and geography 32 within the band form the benchmarked peer set.

Distribution of comparable compensation

$47,655 total compensation of comparable organizations → $881,695 $176,371
$191,38610th
$271,48925th
$321,092Median
$399,28775th
$526,22590th
$176,371This org · 6th
p10$191,386
p25$271,489
p50$321,092
p75$399,287
p90$526,225
$176,371

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

OrganizationStateTotal revenueTotal compSource
Community Foundation Of St Joseph County IncIN $61,343,123$354,225 990
Community Foundation For The Fox ValleyWI $60,589,648$457,787 990
Baltimore Community Foundation IncMD $60,559,630$329,146 990
Givewell Community Foundation IncFL $63,733,787$187,812 990
The Dayton FoundationOH $59,281,429$881,695 990
🔒 27 more comparable organizations — included in the purchased report

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 IL 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 default6th
Total compensation (D + F), as reported (no adjustments)9th
Reportable pay only (column D), adjusted6th
All sources (D + E + F), adjusted0th

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 32-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). 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.