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PeerBasis
Compensation Comparability Determination

Fulton Gardens Corporation

Executive Director / CEO

EIN 264518833
TX · NTEE L22
FY ending 2024-12-31
June 9, 2026

This analysis benchmarks the total compensation of Mary Lawler, Executive Director / CEO ($13,180) against every comparable organization that fit the selection criteria — 282 in total — drawn systematically from IRS Form 990 filings, not a hand-picked subset.

Compensation sits at approximately the 15th percentile of comparable organizationsbelow the typical range for comparable organizations

Benchmarked executive: Mary Lawler — reported title “PRESIDENT”, a direct title match to the Executive Director / CEO role.

How comparable organizations were selected

282 organizations qualified on sector, size, and geography 282 within the band form the benchmarked peer set.

Distribution of comparable compensation

$440 total compensation of comparable organizations → $425,433 $13,180
$9,90610th
$22,55925th
$39,046Median
$60,51575th
$80,80390th
$13,180This org · 15th
p10$9,906
p25$22,559
p50$39,046
p75$60,515
p90$80,803
$13,180

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 TX 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
Worthington Christian Village Colony In OH$372,029 Ceo / Exec Dir $9,685 $10,255 2024
Casa De Merced CO$374,114 Vice President $34,402 $33,951 2023
Tri-county Senior Citizens & Housing Inc CO$371,142 Executive Dir. $40,565 $38,885 2024
Syracuse Ymca Senior Citizen Housing NY$370,973 Secretary $28,992 $26,190 2024
Columbus Club Association Of Ysleta TX$370,081 Executive Di $148,210 $148,210 2024
Lutheran Social Services Of Central Ohio OH$369,274 President & Ceo $9,088 $9,906 2023
Springvale Terrace Inc DC$368,647 Ceo $21,998 $19,298 2024
Senior Home Sharing IL$378,659 Executive Dir. $77,440 $76,109 2024
Bivins Village TX$367,173 President $52,498 $52,498 2024
Mercy Place Belmont Inc CO$366,310 Director $34,463 $34,011 2023
Apple Valley Senior Housing Corp Inc NY$366,054 Manager $48,984 $44,249 2024
Riverview Apartments Senior Housing MN$365,928 Executive Vp Of Commonbond $23,297 $23,013 2024
Vernon Senior Citizens Housing FL$380,327 Vice Preside $75,384 $68,971 2025
Lutheran Social Services Of Central Ohio OH$381,394 President & Ceo $9,088 $9,906 2023
Angela Westover Housing Corporation MA$364,203 Chief Executive Officer $16,832 $15,121 2024
National Church Residences Of OH$381,903 President $48,755 $50,292 2025
St Paul's Retirement Homes Foundation CA$363,429 Ceo $20,405 $18,135 2023
Centennial Square MN$363,314 Ceo $39,249 $39,915 2023
Upper South Street Housing Dev Fund NY$363,246 President/ceo $49,310 $45,859 2023
Mesa Senior Meadows CO$362,254 Vice President $35,660 $34,183 2024
Shepherd Oaks West Apartments Inc MN$361,165 President/ceo/administrato $26,425 $26,103 2024
Mason City Rhf Housing Inc CA$387,942 President/ceo $68,128 $58,810 2024
Life Plan Humboldt CA$388,432 Board Member $28,000 $24,171 2024
Pvm Kalamazoo Senior Non Profit Housing Corp MI$389,553 Administrator $61,407 $63,363 2024
Rosewood Court Inc MN$355,963 Ceo Of Bhs $158,313 $161,001 2023

Comp (reported) is the figure on each organization's Form 990 (columns D + F); Comp (adjusted) normalizes it to TX 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 TX 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 default15th
Total compensation (D + F), as reported (no adjustments)15th
Reportable pay only (column D), adjusted0th
All sources (D + E + F), adjusted34th

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 (Mary Lawler) 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 282 similarly situated organizations (Same NTEE sector (L22), nationwide + budget 0.67–1.5× revenue).
  3. The authorized body determined that total compensation of $13,180 is reasonable (approximately the 15th 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.