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PeerBasis
Compensation Comparability Determination

Owners' Counsel Of America Inc

Executive Director / CEO

EIN 651110158
ID · NTEE S41
FY ending 2024-11-30
June 9, 2026

This analysis benchmarks the total compensation of Heather Cunningham, Executive Director / CEO ($67,500) against every comparable organization that fit the selection criteria — 442 in total — drawn systematically from IRS Form 990 filings, not a hand-picked subset.

Compensation sits at approximately the 58th percentile of comparable organizationswithin the typical range

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

How comparable organizations were selected

442 organizations qualified on sector, size, and geography 442 within the band form the benchmarked peer set.

Distribution of comparable compensation

$1 total compensation of comparable organizations → $262,767 $67,500
$12,01110th
$36,00525th
$60,065Median
$83,71175th
$116,12190th
$67,500This org · 58th
p10$12,011
p25$36,005
p50$60,065
p75$83,711
p90$116,121
$67,500

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 ID 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
Shelby County Economic Development Board Inc MO$219,838 Employee $129,386 $132,628 2023
Downtown Moorhead Inc MN$219,938 President/ceo $170,346 $158,228 2024
Missouri Ambulance Association MO$219,053 Executive Director $16,500 $16,428 2024
Ark Residential Assisted Living Asn AR$220,069 Executive Director $132,600 $144,250 2023
Colerain Chamber Of Commerce Inc OH$218,999 President $74,500 $76,367 2023
Adams County Chamber Of Commerce Inc WI$220,256 Executive Director $50,000 $49,087 2024
Greater Fairbanks Board Of Realtors AK$220,348 Executive Di $85,522 $76,860 2024
Missouri State Assessors Association MO$220,614 Secretary $300 $299 2024
Georgia Head Start Association Inc GA$221,542 Executive Director $67,371 $63,678 2024
Oregon Cheese Guild OR$217,494 Executive Director $84,000 $73,330 2024
Austin Chamber Of Commerce IL$217,403 Executive Dir. $27,650 $29,580 2021
Germantown Area Chamber Of Commerce WI$217,363 Executive Direc $46,050 $45,209 2024
Real Estate Association Of Puget Sound WA$221,839 Chairman $70,900 $61,433 2023
Bedford Chamber Of Commerce Inc VA$221,895 President $55,108 $51,496 2023
Rogue Valley Vintners OR$222,028 Executive Director $80,500 $72,350 2023
Procedure Professionals Association Inc FL$217,027 Owner $1,800 $1,590 2024
Nw High Performance OR$222,514 Executive Dir. $134,514 $120,895 2023
Culver City Arts District CA$216,320 Executive Dir. $12,368 $10,336 2023
National Association Of Certified TX$216,295 Executive Dir. $100,000 $94,033 2024
The Lower Niagara River Region Chamber NY$222,922 Past President $82,458 $70,043 2024
Next Generation In Trucking Association KY$223,098 President $141,413 $147,038 2023
Adult Non-alcoholic Beverage Assoc Inc DE$215,948 Secretary $144,375 $136,814 2023
Central Baldwin Chamber Of Commerce AL$215,769 Executive Director $1 $1 2024
Veterinary Specialty Practice Alliance Inc OH$223,460 Executive Director $62,400 $62,128 2024
Washington Aviation Association WA$215,654 Pres & Treas $37,500 $31,561 2024

Comp (reported) is the figure on each organization's Form 990 (columns D + F); Comp (adjusted) normalizes it to ID 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 ID 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 default58th
Total compensation (D + F), as reported (no adjustments)53rd
Reportable pay only (column D), adjusted59th
All sources (D + E + F), adjusted55th

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 (Heather Cunningham) 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 442 similarly situated organizations (Same NTEE sector (S41), nationwide + budget 0.67–1.5× revenue).
  3. The authorized body determined that total compensation of $67,500 is reasonable (approximately the 58th 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.