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PeerBasis
Compensation Comparability Determination

St James Group Inc

Executive Director / CEO

EIN 611367385
KY · NTEE L20
FY ending 2023-12-31
June 9, 2026

This analysis benchmarks the total compensation of Dr Harriet Wagner, Executive Director / CEO ($2,126) against every comparable organization that fit the selection criteria — 33 in total — drawn systematically from IRS Form 990 filings, not a hand-picked subset.

Compensation sits at approximately the 3rd percentile of comparable organizationsbelow the typical range for comparable organizations

Benchmarked executive: Dr Harriet Wagner — reported title “PRESIDENT/CEO”, a direct title match to the Executive Director / CEO role.

How comparable organizations were selected

33 organizations qualified on sector, size, and geography 33 within the band form the benchmarked peer set.

Distribution of comparable compensation

$2,068 total compensation of comparable organizations → $428,471 $2,126
$8,03910th
$19,08025th
$27,470Median
$40,55275th
$130,63390th
$2,126This org · 3rd
p10$8,039
p25$19,080
p50$27,470
p75$40,552
p90$130,633
$2,126

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
Asset Holdings Inc GA$0 Ceo/director $471,348 $428,471 2024
Provident Group Girard Properties Inc LA$0 President $27,395 $28,078 2023
Douglas Gardens Holding Corp Inc FL$0 President $14,478 $12,297 2024
Fhcsd Housing Inc CA$0 President, Ceo $60,907 $48,953 2023
Cpnj-laurel Inc NJ$0 President - Ceo $19,321 $15,596 2024
Chesapeake Bay Housing Inc VA$0 Chairman $17,050 $14,884 2024
Esperanza Rhf Housing CA$0 President/ceo $76,739 $59,908 2024
Nsi - Lincoln County MO$0 Ceo $5,743 $5,499 2024
Perth Amboy Housing Inc NJ$0 Executive Director $256,277 $206,865 2024
1559 Boone Avenue Housing Development NY$0 Ceo $41,741 $34,100 2024
Menorah Plaza Housing Corporation MN$0 Ceo $22,194 $19,826 2024
Pine Gardens Ii Inc CA$0 Cfo $32,291 $25,209 2024
George Street Housing Inc MA$0 President $43,890 $35,657 2024
Wca Development Corporation CA$0 President $29,978 $23,403 2024
Visitacion Valley Affordable Housing CO$0 President $22,009 $19,080 2024
Tulsa Community Loan Fund Inc OK$0 Executive Director $21,922 $21,824 2024
Meadow On Seneca Housing Development NY$0 President $35,098 $28,673 2024
Corona-ely Ranch Inc CA$0 President $39,896 $31,145 2024
Greater Rochester Partnership NY$0 President $26,994 $22,053 2024
Supportive Housing Inc TX$0 President And Ceo $44,840 $40,552 2024
Ccbc Properties Inc MA$0 President & Ceo $28,286 $22,387 2025
Hdf Community Land Trust Inc CT$0 President & Secretary $8,446 $6,975 2025
Icl Southern Boulevard Housing NY$0 Chair Person $25,107 $21,117 2023
Cucs Housing Development Fund NY$0 President $46,481 $39,094 2023
Vanguard Housing Solutions Inc GA$0 Former Presi $2,210 $2,068 2023

Comp (reported) is the figure on each organization's Form 990 (columns D + F); Comp (adjusted) normalizes it to KY 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 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 default3rd
Total compensation (D + F), as reported (no adjustments)0th
Reportable pay only (column D), adjusted0th
All sources (D + E + F), adjusted30th

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 (Dr Harriet Wagner) 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 33 similarly situated organizations (Same NTEE sector (L20), nationwide + budget 0.67–1.5× revenue).
  3. The authorized body determined that total compensation of $2,126 is reasonable (approximately the 3rd 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.