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PeerBasis
Compensation Comparability Determination

Rock Garden Camp

Executive Director / CEO

EIN 431599515
MO · NTEE L80Z
FY ending 2024-09-30
June 9, 2026

This analysis benchmarks the total compensation of Mark Willbanks, Executive Director / CEO ($18,600) 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 23rd percentile of comparable organizationsbelow the typical range for comparable organizations

Benchmarked executive: Mark Willbanks — reported title “MANAGER”, selected as the organization's highest-paid individual — no exact title match, so confirm this is a comparable 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

$735 total compensation of comparable organizations → $162,496 $18,600
$11,70810th
$19,07225th
$32,849Median
$57,67175th
$77,02190th
$18,600This org · 23rd
p10$11,708
p25$19,072
p50$32,849
p75$57,671
p90$77,021
$18,600

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 MO 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
Stones River Development Corporation TN$189,803 Executive Director $29,224 $28,256 2025
Ingraham Housing Corporation ME$191,409 President $15,951 $15,080 2024
The Safe Place Foundation IA$186,798 Executive Director $42,780 $45,532 2023
Vesta Three Inc MD$183,633 President $21,417 $18,905 2024
Mp Mezes Inc CA$181,422 Cfo/assistant Secretary $59,660 $50,076 2023
Cmrs Iv Inc NH$181,273 President & Ceo $32,010 $27,906 2024
Friendsvva Apartments Inc OH$199,654 Director/president $24,254 $24,254 2024
His Daughters House CA$180,015 Ceo $20,097 $16,869 2023
Lotus Care House MO$179,774 Executive Director $77,885 $80,186 2023
Affordable Housing Association CA$200,264 Ceo $23,461 $19,127 2024
Mental Health Programs Inc Vi MA$200,470 President $12,032 $9,945 2025
Mobility Special Care Housing Inc NJ$201,437 President $72,000 $60,694 2024
Abigail's Place TX$177,282 Executive Director $48,000 $45,333 2024
Bil Housing Development Fund Co Inc NY$202,828 Board Member/president $27,794 $23,102 2025
The Pec Foundation PA$203,812 President - Hopephl $11,844 $11,481 2023
Stephenson Place AZ$204,870 Chief Executive Officer $7,199 $6,730 2023
Fair Housing Center Of Northern Alabama AL$206,697 Executive Director $56,438 $57,567 2024
Highview Unity Apartments Inc WV$207,299 President $53,483 $54,674 2024
Cloville Homes Inc MD$207,683 Treasurer $28,731 $25,361 2024
Strategic Community Investments AR$172,088 Exec Dir/sec $22,377 $24,450 2023
Dh Inc OR$170,222 President $15,031 $13,568 2023
Clean House Recovery Inc MA$213,301 Senior Director $45,022 $38,198 2024
The Rise Center OH$165,354 President/ceo $76,379 $76,379 2024
Narragansett Affordable Housing Inc RI$163,584 President $37,500 $33,074 2025
Prairie Haven Inc IA$162,717 Top Management Official $19,545 $20,802 2023

Comp (reported) is the figure on each organization's Form 990 (columns D + F); Comp (adjusted) normalizes it to MO 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 MO 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 default23rd
Total compensation (D + F), as reported (no adjustments)22nd
Reportable pay only (column D), adjusted64th
All sources (D + E + F), adjusted6th

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 (Mark Willbanks) 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 (L80), nationwide + budget 0.67–1.5× revenue).
  3. The authorized body determined that total compensation of $18,600 is reasonable (approximately the 23rd 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.