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PeerBasis
Compensation Comparability Determination

Mille Lacs Trails Inc

Executive Director / CEO

EIN 411864766
MN · NTEE S12
FY ending 2023-12-31
June 9, 2026

This analysis benchmarks the total compensation of John Coombs, Executive Director / CEO ($19,519) against every comparable organization that fit the selection criteria — 16 in total — drawn systematically from IRS Form 990 filings, not a hand-picked subset.

Compensation sits at approximately the 31st percentile of comparable organizationswithin the typical range

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

How comparable organizations were selected

16 organizations qualified on sector, size, and geography 16 within the band form the benchmarked peer set.

Distribution of comparable compensation

$3,493 total compensation of comparable organizations → $87,058 $19,519
$7,51510th
$12,49725th
$35,654Median
$58,00875th
$74,04690th
$19,519This org · 31st
p10$7,515
p25$12,497
p50$35,654
p75$58,008
p90$74,046
$19,519

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
One Family Productions VA$225,753 Executive Director $12,150 $11,531 2024
Las Vegas New Mexico Community Foun NM$234,504 Executive Di $11,777 $12,819 2023
Invest Buffalo Niagara Foundation Inc NY$221,253 President & Ceo $40,239 $35,743 2024
Olympia Center Inc FL$240,797 Executive Director $34,000 $31,398 2024
Tri-county Economic Development KY$254,784 President $10,222 $10,796 2024
Love In The Name Of Christ Of Yakima WA$254,990 Executive Dir. $57,289 $51,908 2023
Eagle Ranch Housing Corporation CO$187,182 Administrator $3,600 $3,493 2023
Kankakee Riverfront Society Inc IL$269,393 Executive Dir. $87,500 $87,058 2023
Brilliance Labs OR$184,887 President And Executive Director $48,900 $45,958 2023
Nuvista Light & Electric Cooperative Inc AK$275,014 Executive Director $90,874 $85,403 2024
Hoover Helps AL$180,024 Executive Director $53,511 $56,827 2024
Fernandina Beach Main Street FL$280,800 Executive Di $66,654 $61,552 2024
Snow Approach Foundation Inc NC$304,863 Board Chair $4,168 $4,233 2024
Haitian American Center For Social Economic Dev Az AZ$308,687 Executive Director $36,541 $35,565 2023
Bipoc Support Foundation CA$326,085 Executive Dir. $73,855 $62,689 2024
Ndn Fund Inc SD$337,231 Managing Director $25,501 $27,665 2024

Comp (reported) is the figure on each organization's Form 990 (columns D + F); Comp (adjusted) normalizes it to MN 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 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 default31st
Total compensation (D + F), as reported (no adjustments)31st
Reportable pay only (column D), adjusted44th
All sources (D + E + F), adjusted19th

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 (John Coombs) 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 16 similarly situated organizations (Same NTEE sector (S12), nationwide + budget 0.67–1.5× revenue).
  3. The authorized body determined that total compensation of $19,519 is reasonable (approximately the 31st 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.