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PeerBasis
Compensation Comparability Determination

Cls Holding Company Inc

Executive Director / CEO

EIN 383522198
MI · NTEE S47
FY ending 2024-09-30
June 9, 2026

This analysis benchmarks the total compensation of Annette Downey, Executive Director / CEO ($33,282) against every comparable organization that fit the selection criteria — 64 in total — drawn systematically from IRS Form 990 filings, not a hand-picked subset.

Compensation sits at approximately the 42nd percentile of comparable organizationswithin the typical range

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

How comparable organizations were selected

64 organizations qualified on sector, size, and geography 64 within the band form the benchmarked peer set.

Distribution of comparable compensation

$375 total compensation of comparable organizations → $959,206 $33,282
$7,79910th
$19,64825th
$47,372Median
$81,58975th
$135,60190th
$33,282This org · 42nd
p10$7,799
p25$19,648
p50$47,372
p75$81,589
p90$135,601
$33,282

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 MI 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
Union Building Fund IL$479,140 Director $85,479 $81,417 2024
Iron Workers' Mid-america Building Corp IL$487,245 Administrator $56,655 $55,556 2023
U A Local 773 Glens Falls Building NY$470,773 Director $114,100 $99,891 2024
Local 338 Real Estate Holding Corp NY$469,750 President $72,825 $63,756 2024
Ua 168 Building Corporation OH$468,917 Financial Secretary/treasu $92,850 $92,822 2025
Simple Treasures Inc MI$497,014 President $25,217 $25,217 2024
Burnham Brook Community Center Title MI$454,892 President/ceo - Partial Year $7,908 $7,704 2025
Tac East Holdings Company No 1 TX$450,415 President $19,813 $19,768 2023
Naiop - Nashville Chapter TN$525,146 Executive Director $170,265 $178,516 2023
Sheet Metal Workers International Local MA$526,146 President $133,450 $116,183 2024
Little Rock Realtors Association Inc AR$528,403 Executive Dir. $113,589 $123,700 2024
Broadway Housing Sugar Hill Lessee Inc NY$429,087 Chief Executive Officer $31,386 $27,477 2024
Haines Eastburn Stenton Corp PA$531,149 President/ceo $11,512 $11,451 2023
Portland Board Of Realtors ME$532,840 Ceo $114,201 $110,790 2024
Iupat District Council 78 Propertiesinc FL$538,742 Business Manager $62,675 $57,043 2024
Wci Real Estate & Logistics Inc MD$540,000 National Accountant $60,000 $54,346 2024
Teamsters Local 120 Building Holding Company MN$417,127 President $62,448 $61,549 2023
Empire State Carpenters NY$542,116 Treasurer/trustee $61,051 $53,448 2024
Institute Of Real Estate Management MA$414,104 Executive Director $156,975 $140,701 2023
Local Union 488 Ibew Building CT$410,560 Business Manager/fin Sec $70,615 $66,041 2023
Camelot Community Care Property FL$407,194 President/ Ceo $400 $375 2023
Local 5 Holdings Inc HI$406,996 Chair $28,166 $24,431 2024
Api Nevada Properties Inc NV$556,604 President $183,105 $183,071 2023
Service Employees International MN$396,068 President $66,844 $63,991 2024
Salamander Realty Corp NY$563,923 President $3,964 $3,470 2024

Comp (reported) is the figure on each organization's Form 990 (columns D + F); Comp (adjusted) normalizes it to MI 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 MI 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 default42nd
Total compensation (D + F), as reported (no adjustments)41st
Reportable pay only (column D), adjusted0th
All sources (D + E + F), adjusted67th

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 (Annette Downey) 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 64 similarly situated organizations (Same NTEE sector (S47), nationwide + budget 0.67–1.5× revenue).
  3. The authorized body determined that total compensation of $33,282 is reasonable (approximately the 42nd 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.