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PeerBasis
Compensation Comparability Determination

Constitutional Rights Foundation Of

Executive Director / CEO

EIN 330068500
CA · NTEE R600
FY ending 2024-06-30
June 9, 2026

This analysis benchmarks the total compensation of Shara Beral Witkin, Executive Director / CEO ($64,266) against every comparable organization that fit the selection criteria — 24 in total — drawn systematically from IRS Form 990 filings, not a hand-picked subset.

Compensation sits at approximately the 33rd percentile of comparable organizationswithin the typical range

Benchmarked executive: Shara Beral Witkin — reported title “EXECUTIVE DIRECTOR”, a direct title match to the Executive Director / CEO role.

How comparable organizations were selected

24 organizations qualified on sector, size, and geography 24 within the band form the benchmarked peer set.

Distribution of comparable compensation

$10,959 total compensation of comparable organizations → $232,606 $64,266
$18,33810th
$52,32625th
$90,377Median
$139,35075th
$185,16290th
$64,266This org · 33rd
p10$18,338
p25$52,326
p50$90,377
p75$139,350
p90$185,162
$64,266

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 CA 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
National Council On Civil Advocacy Inc DC$389,315 Executive Officer $86,194 $90,182 2023
Fpc Action Foundation NV$407,462 Vp/gc Thru 3/24, President From 3/24 $200,380 $232,606 2024
Florida Impact Inc FL$414,959 President/ce $92,240 $103,315 2023
Advocates For Trans Equality NY$424,852 Executive Director $21,038 $22,016 2024
Zachor Legal Institute MT$324,448 President $30,000 $37,450 2024
Ceasefire Pennsylvania PA$322,328 Executive Di $11,954 $14,213 2023
National Whistleblower Center DC$439,947 Executive Dir. $182,358 $185,320 2024
We The Patriots Usa Inc ID$311,241 President $150,000 $184,792 2024
Maryland Rise Inc MD$448,800 Former Executive Director $52,272 $58,266 2023
The National Center For Law And Policy CA$299,784 President $219,646 $226,134 2023
Knife Rights Inc AZ$296,945 Chairman/ceo $15,050 $16,762 2024
National Center For Justice And Liberty IL$466,432 President $118,059 $134,413 2024
Texans For Vaccine Choice Education TX$292,608 Secretary $72,583 $84,083 2024
American Firearms Coalition OH$468,236 Secretary $38,000 $47,986 2023
Missouri Civil Justice Reform MO$284,500 Executive Dir. $120,000 $151,537 2023
American Values Action VA$475,903 President $81,000 $90,572 2024
Mi Patria Pr PR$270,393 Co-chair & Treasurer $11,249 $10,959 2025
Public Accountability OR$269,630 Secretaryexecutive Director $50,000 $53,773 2024
Center For Justice And Democracy NY$269,313 President $150,000 $156,970 2024
Skylight Engagement Inc NY$497,627 Executive Dir. $82,225 $86,046 2024
Human & Civil Rights Organizations MA$505,816 Executive Di $84,750 $88,196 2024
Calling All Crows Inc MA$529,796 Former Exec Dir $130,000 $135,287 2024
Surveillance Technology Oversight NY$532,329 Executive Director $108,741 $117,155 2023
Lagniappe Law Lab LA$560,147 Executive Director $100,500 $131,942 2023

Comp (reported) is the figure on each organization's Form 990 (columns D + F); Comp (adjusted) normalizes it to CA 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 CA 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 default33rd
Total compensation (D + F), as reported (no adjustments)33rd
Reportable pay only (column D), adjusted33rd
All sources (D + E + F), adjusted25th

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 (Shara Beral Witkin) 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 24 similarly situated organizations (Same NTEE sector (R60), nationwide + budget 0.67–1.5× revenue).
  3. The authorized body determined that total compensation of $64,266 is reasonable (approximately the 33rd 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.