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PeerBasis
Compensation Comparability Determination

Duluth Library Foundation

Executive Director / CEO

EIN 411696460
MN · NTEE B70Z
FY ending 2024-12-31
June 9, 2026

This analysis benchmarks the total compensation of Erin Kreeger, Executive Director / CEO ($77,692) against every comparable organization that fit the selection criteria — 59 in total — drawn systematically from IRS Form 990 filings, not a hand-picked subset.

Compensation sits at approximately the 53rd percentile of comparable organizationswithin the typical range

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

How comparable organizations were selected

59 organizations qualified on sector, size, and geography 59 within the band form the benchmarked peer set.

Distribution of comparable compensation

$2,375 total compensation of comparable organizations → $159,916 $77,692
$41,27210th
$55,70025th
$69,963Median
$95,74975th
$114,03590th
$77,692This org · 53rd
p10$41,272
p25$55,700
p50$69,963
p75$95,749
p90$114,035
$77,692

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 MN 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
Community Library Of The Shenango Valley PA$617,011 Library Director $71,211 $71,868 2024
Garden Home Community Library OR$624,140 Executive Dir. $98,914 $92,962 2024
Dansville Public Library NY$633,649 New Director $55,763 $52,501 2023
Ruth Keeler Memorial Library NY$640,904 Library Director $106,392 $97,295 2024
Millinocket Memorial Library ME$589,365 Library Director $66,560 $67,451 2024
🔒 54 more comparable organizations — included in the purchased report

Comp (reported) is the figure on each organization's Form 990 (columns D + F); Comp (adjusted) normalizes it to MN 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 MN 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 default53rd
Total compensation (D + F), as reported (no adjustments)58th
Reportable pay only (column D), adjusted54th
All sources (D + E + F), adjusted49th

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:

Ready-to-adopt board minutes — executive compensation

🔒 The complete minutes language — three numbered resolutions pre-filled with this organization, the 59-organization comparison, the date, and the percentile finding, ready to paste into your minutes — is included in the purchased report.

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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.