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PeerBasis
Compensation Comparability Determination

South Carolina First Steps To

Executive Director / CEO

EIN 571097778
SC · NTEE B012
FY ending 2023-06-30
June 10, 2026

This analysis benchmarks the total compensation of Tricia Gordon, Executive Director / CEO ($1,732) against every comparable organization that fit the selection criteria — 88 in total — drawn systematically from IRS Form 990 filings, not a hand-picked subset.

Compensation sits at approximately the 2nd percentile of comparable organizationsbelow the typical range for comparable organizations

Benchmarked executive: Tricia Gordon — reported title “EXECUTIVE DI”, a direct title match to the Executive Director / CEO role.

How comparable organizations were selected

88 organizations qualified on sector, size, and geography 88 within the band form the benchmarked peer set.

Distribution of comparable compensation

$431 total compensation of comparable organizations → $261,698 $1,732
$14,01210th
$51,68125th
$74,366Median
$105,40175th
$139,61790th
$1,732This org · 2nd
p10$14,012
p25$51,681
p50$74,366
p75$105,401
p90$139,617
$1,732

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 SC 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
James Wilson Institute For Natural Rights And The American Founding VA$595,403 Deputy Director $133,560 $120,066 2024
Aligned New Orleans LA$591,715 Ceo $131,250 $138,533 2023
Be Great Together MO$590,943 Executive Director & Secretary $95,000 $93,681 2024
Montgomery County Partnership For NC$603,624 Executive Director $98,122 $97,184 2023
Tenant Education Network IL$607,076 Executive Di $39,115 $36,861 2023
🔒 83 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 SC 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 SC 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 default2nd
Total compensation (D + F), as reported (no adjustments)1st
Reportable pay only (column D), adjusted6th
All sources (D + E + F), adjusted18th

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 88-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 10, 2026.