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PeerBasis
Compensation Comparability Determination

Necog Development Corporation

Executive Director / CEO

EIN 460434487
SD · NTEE W60
FY ending 2024-12-31
June 9, 2026

This analysis benchmarks the total compensation of Todd Garry, Executive Director / CEO ($500) against every comparable organization that fit the selection criteria — 373 in total — drawn systematically from IRS Form 990 filings, not a hand-picked subset.

Compensation sits at approximately the 0th percentile of comparable organizationsbelow the typical range for comparable organizations

Benchmarked executive: Todd Garry — reported title “Director”, selected as the organization's highest-paid individual — no exact title match, so confirm this is a comparable role.

How comparable organizations were selected

373 organizations qualified on sector, size, and geography 373 within the band form the benchmarked peer set.

Distribution of comparable compensation

$786 total compensation of comparable organizations → $773,081 $500
$20,35510th
$48,24125th
$79,153Median
$115,34275th
$150,90490th
$500This org · 0th
p10$20,355
p25$48,241
p50$79,153
p75$115,342
p90$150,904
$500

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 SD 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
Simplifyct Inc CT$662,834 Executive Dir. $111,470 $94,701 2024
Three Rangers Foundation OR$666,830 Executive Director $5,000 $4,207 2024
Midpeninsula Community Media Center Inc CA$667,461 Board Member $65,000 $52,359 2023
Global Liberty Institute Usa DC$660,433 President $60,000 $47,708 2024
American Legion Auxiliary CA$669,285 Secretary $66,560 $52,078 2024
🔒 368 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 SD 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 SD 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 default0th
Total compensation (D + F), as reported (no adjustments)0th
Reportable pay only (column D), adjusted7th
All sources (D + E + F), adjusted0th

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 373-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.