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PeerBasis
Compensation Comparability Determination

Triple Twelve Ministries Inc

Executive Director / CEO

EIN 465767383
KY · NTEE I80
FY ending 2025-08-31
June 9, 2026

This analysis benchmarks the total compensation of Carl L Williams Sr, Executive Director / CEO ($85,231) against every comparable organization that fit the selection criteria — 102 in total — drawn systematically from IRS Form 990 filings, not a hand-picked subset.

Compensation sits at approximately the 52nd percentile of comparable organizationswithin the typical range

Benchmarked executive: Carl L Williams Sr — reported title “EXECUTIVE DIRECTOR”, a direct title match to the Executive Director / CEO role.

How comparable organizations were selected

102 organizations qualified on sector, size, and geography 102 within the band form the benchmarked peer set.

Distribution of comparable compensation

$1,168 total compensation of comparable organizations → $320,374 $85,231
$45,18710th
$65,81425th
$84,692Median
$103,26175th
$134,99690th
$85,231This org · 52nd
p10$45,187
p25$65,814
p50$84,692
p75$103,261
p90$134,996
$85,231

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 KY 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
University Student Legal Services NC$459,750 Attorney $128,596 $130,698 2023
Restoring Justice TX$464,811 Ceo $122,405 $116,983 2024
Energy & Mineral Law Foundation KY$458,300 Executive Director $143,586 $147,385 2024
All For The Family Legal Clinic Inc CA$466,149 Managing Attorney Ceo $94,246 $77,753 2024
South Alabama Volunteer Lawyers Program AL$455,874 Executive Director $70,449 $74,863 2023
Christian Legal Clinics Of Philadelphia PA$455,121 Executive Director $92,475 $88,107 2024
Innocent MI$452,829 President $88,000 $86,780 2024
Steen Mountain Defenders OR$471,908 Ex Director $95,046 $84,329 2024
Access The Law OR$472,403 Excutive Director $113,377 $103,564 2023
Casa Of Grant County Inc IN$448,126 Executive Director $67,097 $69,600 2023
Software Freedom Law Center Inc NY$478,107 Pres, Exec Dir, & Chairman $61,584 $51,797 2025
Open Hands Legal Services Inc NY$443,206 Executive Director $107,981 $95,977 2023
Voices For Children Inc MD$438,297 Executive Director $84,342 $73,394 2025
Annapolis Immigration Justice Network Inc MD$437,410 Executive Director From June 2023 $52,613 $48,383 2023
Choosing Justice Initiative TN$436,697 President $101,093 $101,524 2024
Step Up To Justice AZ$488,880 Executive Director $90,176 $82,857 2024
Arizona Senior Citizens AZ$424,724 Interim Dire $103,514 $95,113 2024
The Liberty Initiative Inc AR$424,640 Executive Di $47,800 $51,334 2024
Gallia County Defense Attorney Corp OH$420,000 President $122,959 $124,425 2024
Inner Banks Legal Services NC$417,113 Excutive Dir $61,439 $60,652 2024
Student Legal Services NC$507,722 Director $174,472 $172,237 2024
A Legacy Of Equality Leadership And Organizing WA$415,878 Executive Director $84,075 $71,916 2024
Indian Legal Assistance Program MN$508,568 Executive Di $105,043 $96,610 2025
Miracle Of Innocence Inc KS$413,890 President $45,000 $46,448 2024
Szuba Guardian Care Solutions Inc FL$512,833 President $72,356 $64,941 2024

Comp (reported) is the figure on each organization's Form 990 (columns D + F); Comp (adjusted) normalizes it to KY cost of living and 2025 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 KY 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 default52nd
Total compensation (D + F), as reported (no adjustments)44th
Reportable pay only (column D), adjusted60th
All sources (D + E + F), adjusted49th

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 (Carl L Williams Sr) 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 102 similarly situated organizations (Same NTEE sector (I80), nationwide + budget 0.67–1.5× revenue).
  3. The authorized body determined that total compensation of $85,231 is reasonable (approximately the 52nd 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.