Live preview — download the board-ready PDF to attach to your minutes.Download the free PDF
Email yourself a copy:
PeerBasis
Compensation Comparability Determination

Fpc Action Foundation

Executive Director / CEO

EIN 472471253
NV · NTEE R60
FY ending 2024-12-31
June 9, 2026

This analysis benchmarks the total compensation of Cody Wisniewski, Executive Director / CEO ($200,380) against every comparable organization that fit the selection criteria — 26 in total — drawn systematically from IRS Form 990 filings, not a hand-picked subset.

Compensation sits at approximately the 100th percentile of comparable organizationsabove the 90th percentile — board review recommended

Benchmarked executive: Cody Wisniewski — reported title “VP/GC THRU 3/24, PRESIDENT FROM 3/24”, selected as the organization's highest-paid individual — no exact title match, so confirm this is a comparable role.

How comparable organizations were selected

26 organizations qualified on sector, size, and geography 26 within the band form the benchmarked peer set.

Distribution of comparable compensation

$2,735 total compensation of comparable organizations → $194,805 $200,380
$16,50210th
$34,53125th
$76,833Median
$115,25975th
$152,30490th
$200,380This org · 100th
p10$16,502
p25$34,531
p50$76,833
p75$115,259
p90$152,304
$200,380

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 NV 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
Florida Impact Inc FL$414,959 President/ce $92,240 $89,001 2023
Advocates For Trans Equality NY$424,852 Executive Director $21,038 $18,965 2024
National Council On Civil Advocacy Inc DC$389,315 Executive Officer $86,194 $77,688 2023
Constitutional Rights Foundation Of CA$379,628 Executive Director $64,266 $55,362 2024
National Whistleblower Center DC$439,947 Executive Dir. $182,358 $159,646 2024
Maryland Rise Inc MD$448,800 Former Executive Director $52,272 $50,194 2023
National Center For Justice And Liberty IL$466,432 President $118,059 $115,791 2024
American Firearms Coalition OH$468,236 Secretary $38,000 $41,338 2023
American Values Action VA$475,903 President $81,000 $78,024 2024
Zachor Legal Institute MT$324,448 President $30,000 $32,262 2024
Ceasefire Pennsylvania PA$322,328 Executive Di $11,954 $12,244 2023
Skylight Engagement Inc NY$497,627 Executive Dir. $82,225 $74,125 2024
We The Patriots Usa Inc ID$311,241 President $150,000 $159,190 2024
Human & Civil Rights Organizations MA$505,816 Executive Di $84,750 $75,977 2024
The National Center For Law And Policy CA$299,784 President $219,646 $194,805 2023
Knife Rights Inc AZ$296,945 Chairman/ceo $15,050 $14,440 2024
Texans For Vaccine Choice Education TX$292,608 Secretary $72,583 $72,434 2024
Calling All Crows Inc MA$529,796 Former Exec Dir $130,000 $116,543 2024
Missouri Civil Justice Reform MO$284,500 Executive Dir. $120,000 $130,542 2023
Surveillance Technology Oversight NY$532,329 Executive Director $108,741 $100,924 2023
Lagniappe Law Lab LA$560,147 Executive Director $100,500 $113,662 2023
Global Americans Inc NY$580,449 Executive Director $20,000 $18,563 2023
Ohioans To Stop Executions OH$583,166 Exec Directo $21,023 $22,214 2024
Michigan Voting Rights Foundation MI$595,000 Treasurer/secretary $2,580 $2,735 2023
Rocky Mountain Innocence Center UT$604,231 Executive Di $138,333 $145,417 2023

Comp (reported) is the figure on each organization's Form 990 (columns D + F); Comp (adjusted) normalizes it to NV 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 NV 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 default100th
Total compensation (D + F), as reported (no adjustments)96th
Reportable pay only (column D), adjusted96th
All sources (D + E + F), adjusted100th

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 (Cody Wisniewski) 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 26 similarly situated organizations (Same NTEE sector (R60), nationwide + budget 0.67–1.5× revenue).
  3. The authorized body determined that total compensation of $200,380 is reasonable (approximately the 100th 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.