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PeerBasis
Compensation Comparability Determination

Equal Citizens Foundation

Executive Director / CEO

EIN 823949758
DC · NTEE I80
FY ending 2024-12-31
June 9, 2026

This analysis benchmarks the total compensation of Phoebe T Wong, Executive Director / CEO ($36,000) against every comparable organization that fit the selection criteria — 72 in total — drawn systematically from IRS Form 990 filings, not a hand-picked subset.

Compensation sits at approximately the 11th percentile of comparable organizationsbelow the typical range for comparable organizations

Benchmarked executive: Phoebe T Wong — reported title “TREASURER”, selected as the organization's highest-paid individual — no exact title match, so confirm this is a comparable role.

How comparable organizations were selected

72 organizations qualified on sector, size, and geography 72 within the band form the benchmarked peer set.

Distribution of comparable compensation

$3,866 total compensation of comparable organizations → $463,608 $36,000
$33,62810th
$53,90025th
$78,681Median
$103,75975th
$131,33590th
$36,000This org · 11th
p10$33,628
p25$53,900
p50$78,681
p75$103,759
p90$131,335
$36,000

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
Frontline Legal Services LA$268,828 Co-executive Director $75,000 $94,111 2024
Allegany Law Foundation Inc MD$268,405 Executive Director $57,073 $62,601 2023
Wyoming County - Attica Legal Aid NY$267,246 Vice Preside $31,756 $31,857 2025
El Centro Hispanoamericano NJ$264,706 Executive Director $49,660 $50,526 2024
Oregon Health Justice Center OR$263,336 Attorney/partner $105,769 $111,931 2024
Phoenix Legal Action Network AZ$261,916 Executive Director $81,222 $91,644 2023
Great Lakes Expungement Network MI$258,107 Executive Director $40,516 $47,656 2024
Lex Mundi Pro Bono Foundation DC$257,339 Managing Dir $132,000 $132,000 2024
Washington Wage Claim Project WA$281,506 Staff Attorney $183,961 $187,688 2024
Peoples Law Center WI$281,834 Executive Director $138,000 $169,087 2023
Lex Rex Institute CA$281,879 Ceo And Attorney $471,140 $463,608 2024
Columbia Gorge Casa OR$282,100 Executive Dir. $59,267 $62,720 2024
New Covenant Legal Services MO$256,169 Executive Di $60,000 $72,418 2024
Montgomery County Bar Foundation AL$283,016 Executive Director $90,360 $111,243 2024
Pikes Peak Justice & Pro Bono Center CO$255,069 Executive Director $74,255 $81,139 2024
Opening Doors International Services Inc TX$251,057 Executive Dir. $55,000 $62,695 2024
The Rise Foundation By Envoy Inc IL$250,000 President And Executive Directo $132,563 $152,901 2023
South Lake Tahoe Family Resource Center CA$288,622 Executive Dir. $50,002 $50,656 2023
Columbia Basin Dispute Resolution Center WA$288,772 Executive Dir. $53,000 $55,670 2023
Legal Assistance Of Dakota County MN$293,191 Executive Di $88,625 $102,741 2023
Justice For Our Neighbors Of The PA$294,362 Executive Dir. $32,917 $38,512 2023
Benton Franklin Legal Aid Society WA$294,679 Executive Dir. $63,815 $65,108 2024
Community Mediation Dc DC$296,363 Former Executive Director $59,701 $59,701 2024
Cottage Street Youth Law OR$241,380 Executive Director $102,200 $108,154 2024
Wyoming Childrens Law Center WY$298,593 Executive Director And Ex Officio Board Member $113,980 $143,194 2023

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 default11th
Total compensation (D + F), as reported (no adjustments)15th
Reportable pay only (column D), adjusted13th
All sources (D + E + F), adjusted6th

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 (Phoebe T Wong) 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 72 similarly situated organizations (Same NTEE sector (I80), nationwide + budget 0.67–1.5× revenue).
  3. The authorized body determined that total compensation of $36,000 is reasonable (approximately the 11th 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.