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PeerBasis
Compensation Comparability Determination

Innovation Law Lab

Executive Director / CEO

EIN 471012852
OR · NTEE R20
FY ending 2023-06-30
June 9, 2026

This analysis benchmarks the total compensation of Stephen Manning, Executive Director / CEO ($126,410) against every comparable organization that fit the selection criteria — 25 in total — drawn systematically from IRS Form 990 filings, not a hand-picked subset.

Compensation sits at approximately the 20th percentile of comparable organizationsbelow the typical range for comparable organizations

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

How comparable organizations were selected

25 organizations qualified on sector, size, and geography 25 within the band form the benchmarked peer set.

Distribution of comparable compensation

$28,123 total compensation of comparable organizations → $522,454 $126,410
$59,85010th
$187,80325th
$235,159Median
$340,03175th
$436,39490th
$126,410This org · 20th
p10$59,850
p25$187,803
p50$235,159
p75$340,031
p90$436,394
$126,410

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 OR 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
Foundation For The Restoration Of America IL$9,428,990 Executive Director(until August 2023) $31,303 $33,139 2023
Cair-foundation Inc DC$9,379,629 Executive Director $272,620 $250,221 2024
Working Hero Action CA$9,707,606 Secretary/treasurer $79,827 $77,270 2022
Care In Action Inc NY$9,722,435 Executive Director (From 12/17/24) $29,756 $28,123 2024
National Asian Pacific American Women's IL$9,740,263 Executive Director $430,490 $442,661 2024
🔒 20 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 OR 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 OR 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 default20th
Total compensation (D + F), as reported (no adjustments)20th
Reportable pay only (column D), adjusted24th
All sources (D + E + F), adjusted12th

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 25-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.