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PeerBasis
Compensation Comparability Determination

White's Livery Housing Development

Executive Director / CEO

EIN 352422011
NY · NTEE L20
FY ending 2023-12-31
June 9, 2026

This analysis benchmarks the total compensation of Kelley Swann, Executive Director / CEO ($7,500) against every comparable organization that fit the selection criteria — 21 in total — drawn systematically from IRS Form 990 filings, not a hand-picked subset.

Compensation sits at approximately the 5th percentile of comparable organizationsbelow the typical range for comparable organizations

How comparable organizations were selected

21 organizations qualified on sector, size, and geography 21 within the band form the benchmarked peer set.

Distribution of comparable compensation

$2,057 total compensation of comparable organizations → $175,264 $7,500
$23,91810th
$32,66025th
$60,217Median
$71,18775th
$106,87290th
$7,500This org · 5th
p10$23,918
p25$32,660
p50$60,217
p75$71,187
p90$106,872
$7,500

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

OrganizationStateTotal revenueTotal compSource
Aim Community Living IncNY $108,072$35,624 990
Habitat For Humanity Of GeneseeNY $103,514$50,860 990
Share Xi IncNY $113,510$70,564 990
Mental Retardation Community Services Of Nassau County-projectNY $113,605$174,603 990
Share Viii IncNY $95,316$70,564 990
Episcopal Community Housing DevelopmentNY $95,006$23,918 990
Community Partnership DevelopmentNY $94,843$40,688 990
White Plains Housing DevelopmentNY $94,046$11,759 990
Phipps Affordable Housing Support CorpNY $122,719$175,264 990
Habitat For Humanity Housing DevelopmentNY $87,385$32,660 990
Community Residence For The HandicappedNY $87,120$106,872 990
202 West 108 Street Hdfc IncNY $85,011$24,995 990
Housing Works Pitkin Avenue Hdfc IncNY $83,738$27,348 990
Share Ix IncNY $80,338$70,564 990
Tsi Properties I IncNY $73,522$100,627 990
721 East 6th Street Housing DevelopmentNY $73,334$2,057 990
Jamestown Affordable Housing IncNY $72,808$38,839 990
Main-ferry Housing Development FundNY $72,018$101,464 990
Ocl Properties Xi IncNY $141,772$71,187 990
Ocl Properties Ix IncNY $147,783$71,187 990
East 54th Street Housing DevelopmentNY $149,704$60,217 990

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 NY 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 default5th
Total compensation (D + F), as reported (no adjustments)5th
Reportable pay only (column D), adjusted0th
All sources (D + E + F), adjusted14th

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 (Kelley Swann) 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 21 similarly situated organizations (Same NTEE sector (L20) + NY + budget 0.67–1.5× revenue).
  3. The authorized body determined that total compensation of $7,500 is reasonable (approximately the 5th 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). 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.