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PeerBasis
Compensation Comparability Determination

Rule Of Law Defense Fund

Executive Director / CEO

EIN 465130903
DC · NTEE P20
FY ending 2024-12-31
June 9, 2026

This analysis benchmarks the total compensation of David Johnson, Executive Director / CEO ($252,911) against every comparable organization that fit the selection criteria — 438 in total — drawn systematically from IRS Form 990 filings, not a hand-picked subset.

Compensation sits at approximately the 91st percentile of comparable organizationsabove the 90th percentile — board review recommended

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

How comparable organizations were selected

438 organizations qualified on sector, size, and geography 438 within the band form the benchmarked peer set.

Distribution of comparable compensation

$3,718 total compensation of comparable organizations → $698,605 $252,911
$62,25810th
$102,64825th
$139,158Median
$188,31075th
$245,22190th
$252,911This org · 91st
p10$62,258
p25$102,648
p50$139,158
p75$188,310
p90$245,221
$252,911

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 DC 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
Reap Inc OR$4,427,959 President/ce $104,582 $113,944 2023
Moms Against Poverty CA$4,424,936 President & Ceo $80,000 $78,721 2024
Little Brothers - Friends Of The Elderly IL$4,422,500 Chief Executive Officer $352,189 $394,566 2024
University Settlement Inc OH$4,420,380 Executive Director $114,987 $142,885 2023
Jewish Family Service Of Rockland County NY$4,464,983 Ceo $99,485 $102,444 2024
🔒 433 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 DC 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 DC 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 default91st
Total compensation (D + F), as reported (no adjustments)93rd
Reportable pay only (column D), adjusted89th
All sources (D + E + F), adjusted89th

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 438-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.