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PeerBasis
Compensation Comparability Determination

Nellie R Sherwood Trust

Executive Director / CEO

EIN 426061621
IA · NTEE Y33Z
FY ending 2023-12-31
June 9, 2026

This analysis benchmarks the total compensation of Michelle Niermann To 0823, Executive Director / CEO ($119,328) against every comparable organization that fit the selection criteria — 6 in total — drawn systematically from IRS Form 990 filings, not a hand-picked subset.

Compensation sits at approximately the 100th percentile of comparable organizationsabove the 90th percentile — board review recommended

Benchmarked executive: Michelle Niermann To 0823 — reported title “BOARD MEMBER & PRESIDENT/CEO”, a direct title match to the Executive Director / CEO role.

How comparable organizations were selected

6 organizations qualified on sector, size, and geography 6 within the band form the benchmarked peer set.

Distribution of comparable compensation

$1,053 total compensation of comparable organizations → $56,751 $119,328
$1,14810th
$1,57625th
$7,608Median
$19,01475th
$38,94690th
$119,328This org · 100th
p10$1,148
p25$1,576
p50$7,608
p75$19,014
p90$38,946
$119,328

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 IA 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
Girard Cemetery Corporation TX$4,923 Director/secretary/treasurer $1,400 $1,242 2024
Mycap Veba OH$3,066 Chair Person $22,500 $21,140 2024
Fraternal Order Of Eagles Aerie 3137 ME$5,066 Secretary $2,980 $2,579 2025
Employee-contribution Veba Trust Depauw University IN$2,337 Vice President For Finance And Administration (Beginning 7/15/22)) $58,924 $56,751 2023
Eventide Cemetery Trust WV$5,883 Trustee $1,065 $1,053 2023
Semco Energy Inc Non-union Veba Trust MI$7,386 President Us Utilities Director $13,800 $12,636 2024

Comp (reported) is the figure on each organization's Form 990 (columns D + F); Comp (adjusted) normalizes it to IA 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 IA 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 default100th
Total compensation (D + F), as reported (no adjustments)100th
Reportable pay only (column D), adjusted0th
All sources (D + E + F), adjusted83rd

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 (Michelle Niermann To 0823) 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 6 similarly situated organizations (Same NTEE major group (Y), nationwide + budget 0.5–2× revenue).
  3. The authorized body determined that total compensation of $119,328 is reasonable (approximately the 100th 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.