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PeerBasis
Compensation Comparability Determination

The Norml Foundation

Executive Director / CEO

EIN 522021279
DC · NTEE R99
FY ending 2024-12-31
June 9, 2026

This analysis benchmarks the total compensation of Keith Stroup, Executive Director / CEO ($17,500) against every comparable organization that fit the selection criteria — 45 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: Keith Stroup — reported title “VICE PRESIDENT”, selected as the organization's highest-paid individual — no exact title match, so confirm this is a comparable role.

How comparable organizations were selected

45 organizations qualified on sector, size, and geography 45 within the band form the benchmarked peer set.

Distribution of comparable compensation

$748 total compensation of comparable organizations → $231,540 $17,500
$6,45810th
$27,98625th
$70,078Median
$105,40475th
$162,53690th
$17,500This org · 20th
p10$6,458
p25$27,986
p50$70,078
p75$105,404
p90$162,536
$17,500

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 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
Vivante Espero NC$295,530 President $23,086 $27,986 2023
Cross-movement Legacy Initiative CA$290,000 President $205,000 $201,723 2024
Take Back The Court Action Fund CA$315,887 President $22,945 $22,578 2024
Survivor Justice Action Inc TX$317,100 Ceo/secretary $46,354 $52,840 2024
Oklahoma Donor Alliance Inc OK$283,764 Executive Director $84,000 $105,404 2024
Bipartisan Climate Action DC$283,645 President $5,654 $5,654 2024
Alaskans Take A Stand AK$323,150 President $15,000 $16,342 2024
Bayard Rustin Center For Social Justice NJ$325,629 Chief Activist $130,000 $132,268 2024
1 Million Madly Motivated Moms NV$276,045 President $59,583 $68,060 2024
Organization For Polyamory And CA$275,610 Executive Dir. $69,173 $70,078 2023
Dont Shoot Portland OR$273,365 Program Direct $160,000 $174,323 2023
Organize Tennessee TN$334,041 Executive Di $54,450 $69,902 2022
World Without Hate Inc WA$266,442 Founder & President $38,000 $39,915 2023
Formed Foundation DC$255,102 Director $27,500 $27,500 2024
No More A Stranger Foundation UT$254,010 Executive Director $45,831 $53,453 2024
Move To Amend CA$253,286 Director $4,800 $4,863 2023
Brandworkers International Inc NY$355,015 Executive Director $74,972 $79,481 2023
Cuba Study Group Inc DC$246,841 Executive Director $170,984 $176,034 2023
Christian Family Life Services Inc ND$355,938 Director $60,449 $77,828 2023
New York Center For Law & Justice Inc NY$357,362 Executive Director $113,124 $119,929 2023
Oregon Donor Alliance OR$365,500 Executive Director $116,089 $122,853 2024
Leadmo Action MO$234,670 Executive Director $64,174 $79,745 2023
El M0vimiento Sigue Inc CO$234,078 Director $5,000 $5,625 2023
Filipino Migrant Center CA$371,775 Exec Director $101,185 $99,567 2024
50 Roses Foundation MO$226,165 Executive Director $27,500 $33,192 2024

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 default20th
Total compensation (D + F), as reported (no adjustments)20th
Reportable pay only (column D), adjusted29th
All sources (D + E + F), adjusted20th

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 (Keith Stroup) 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 45 similarly situated organizations (Same NTEE sector (R99), nationwide + budget 0.67–1.5× revenue).
  3. The authorized body determined that total compensation of $17,500 is reasonable (approximately the 20th 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.