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PeerBasis
Compensation Comparability Determination

Free Enterprise Foundation Inc

Executive Director / CEO

EIN 364439179
IL · NTEE O115
FY ending 2023-06-30
June 9, 2026

This analysis benchmarks the total compensation of James Dougal Nelson, Executive Director / CEO ($5,205) against every comparable organization that fit the selection criteria — 23 in total — drawn systematically from IRS Form 990 filings, not a hand-picked subset.

Compensation sits at approximately the 0th percentile of comparable organizationsbelow the typical range for comparable organizations

Benchmarked executive: James Dougal Nelson — reported title “SECRETARY”, selected as the organization's highest-paid individual — no exact title match, so confirm this is a comparable role.

How comparable organizations were selected

23 organizations qualified on sector, size, and geography 23 within the band form the benchmarked peer set.

Distribution of comparable compensation

$10,444 total compensation of comparable organizations → $148,659 $5,205
$16,14810th
$18,12225th
$33,270Median
$68,71675th
$118,41590th
$5,205This org · 0th
p10$16,148
p25$18,122
p50$33,270
p75$68,716
p90$118,415
$5,205

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.

OrganizationStateRevenueMatched titleComp
(reported)
Comp
(adjusted)
FY
Friends Of Explorer Post 58 OR$427,852 Executive Director $127,547 $120,481 2023
Gsnetx Stem Center Of Excellence TX$441,487 Ceo $36,402 $35,976 2024
Sisters Unchained Inc MA$449,198 Executive Director $124,069 $110,151 2024
Friends Of The Girl Scouts' Trust CA$449,242 Executive Director $25,655 $21,887 2024
Camp Twin Lakes Foundation Inc GA$456,940 Chief Executive Officer $17,296 $17,182 2024
Boys & Girls Club And Family Center Of Bristol Inc CT$400,000 Chief Executive Officer $160,478 $148,659 2024
Big Brothers Big Sisters Of Miami FL$460,576 President & Ceo $12,086 $11,549 2023
Girl Scouts Of Southern Arizona AZ$390,651 Ceo $16,995 $16,148 2024
Girl Scouts Of Southern Arizona AZ$473,322 Ceo $16,995 $16,148 2024
North Yellowstone Education Foundation MT$383,677 Executive Dir. $45,000 $49,340 2023
Building Futures Inc CA$482,915 President & Ceo $173,481 $148,002 2024
Bgcco Milo-grogan Holding Company OH$373,161 Chief Executive Officer $31,794 $33,270 2024
Friends Of St Lawrence-watts Youth Center CA$363,431 Executive Director $85,234 $70,842 2025
La Fencing Academy Of Pomona CA$360,625 President $21,400 $18,257 2024
Friends Of The Children - OR$358,161 Executive Director $21,321 $19,562 2024
Journeymen Institute WA$353,181 Executive Director $78,571 $71,553 2023
Gillwell Foundation NE$348,947 Secretary/executive Direct $57,264 $62,648 2023
New City Kids Foundation NJ$532,927 President $23,637 $20,851 2024
Will Work For Kids Nonprofit Group Inc FL$325,436 Director $11,253 $10,444 2024
Project Hope Ca Inc CA$558,109 President $47,863 $42,040 2023
Kc United Youth Family Sports & Education Association KS$299,174 Program Director $16,368 $17,987 2023
Right From The Start GA$296,138 Executive Director $67,031 $66,589 2024
Included CA$595,660 President $24,249 $20,687 2024

Comp (reported) is the figure on each organization's Form 990 (columns D + F); Comp (adjusted) normalizes it to IL cost of living and 2023 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 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 default0th
Total compensation (D + F), as reported (no adjustments)0th
Reportable pay only (column D), adjusted0th
All sources (D + E + F), adjusted57th

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 (James Dougal Nelson) 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 23 similarly situated organizations (Same NTEE sector (O11), nationwide + budget 0.67–1.5× revenue).
  3. The authorized body determined that total compensation of $5,205 is reasonable (approximately the 0th 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.