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PeerBasis
Compensation Comparability Determination

Clause 40 Foundation

Executive Director / CEO

EIN 824127219
DC · NTEE I50
FY ending 2023-12-31
June 9, 2026

This analysis benchmarks the total compensation of Shana-tara O'toole, Executive Director / CEO ($5,250) against every comparable organization that fit the selection criteria — 73 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: Shana-tara O'toole — reported title “PRESIDENT/CEO”, a direct title match to the Executive Director / CEO role.

How comparable organizations were selected

73 organizations qualified on sector, size, and geography 73 within the band form the benchmarked peer set.

Distribution of comparable compensation

$4,363 total compensation of comparable organizations → $207,465 $5,250
$10,17210th
$20,25225th
$45,117Median
$68,88575th
$103,81590th
$5,250This org · 3rd
p10$10,172
p25$20,252
p50$45,117
p75$68,885
p90$103,815
$5,250

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
The Foundation In Support Of The MI$99,288 President $20,185 $23,061 2024
Bayberry Courts Inc RI$100,704 President $52,490 $57,356 2023
Finequity Inc NY$100,802 Executive Director $116,040 $116,063 2024
Minnesota Freedom Fund Action MN$101,127 Director Programs Operatio $12,406 $13,568 2024
Foundation Of The Monroe County Bar NY$97,946 Executive Director - Resigned Dec 2024 $17,320 $16,876 2025
Wisconsin Foundation WI$97,733 Executive Di $38,489 $45,806 2023
Community Mediation Services TN$96,987 Executive Director $47,625 $55,411 2024
Citizens For Community Justice Inc IN$103,218 Executive Director $50,000 $58,363 2024
Community Health & Safety AL$95,080 Executive Di $18,822 $22,507 2024
Stop Child Predators Coalition DC$95,000 President $42,000 $40,795 2024
101 Enterprises Foundation CA$94,353 Cfo $30,000 $27,934 2025
Apoyo Legal Al Emprendimiento Comunitario Inc PR$106,009 Director $32,000 $32,000 2023
Pathways For Change Inc FL$106,135 Executive Director $22,237 $23,122 2024
Stop Handgun Violence Inc MA$92,825 Executive Director $52,903 $51,264 2025
Nevada Peace Officer Association NV$107,204 President $9,600 $10,652 2024
Clarinda Youth Corporation IA$108,216 President $3,600 $4,363 2024
The Florida Pdmp Foundation Inc FL$90,382 Executive Director $68,000 $68,885 2025
Racine Neighborhood Watch Inc WI$89,800 Executive Director Thru 6/20/23 $46,452 $55,283 2023
Easterseals Housing Solutions Inc MT$111,085 President/ce $16,543 $19,738 2024
Exoneration Initiative NY$87,791 Founder $100,000 $102,974 2023
Go Reentry Specialists Inc PA$87,700 Executive Di $47,736 $52,691 2024
Parents Against Child Sex Abuse IL$111,911 Executive Director $25,566 $27,821 2024
Spf-iimc IL$112,649 President/ceo $30,975 $34,702 2023
Nofires Inc MA$113,064 Executive Di $54,600 $54,308 2024
Life After Justice IL$113,155 Executive Director $77,184 $83,991 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 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 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 default3rd
Total compensation (D + F), as reported (no adjustments)3rd
Reportable pay only (column D), adjusted0th
All sources (D + E + F), adjusted89th

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 (Shana-tara O'toole) 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 73 similarly situated organizations (Same NTEE major group (I), nationwide + budget 0.67–1.5× revenue).
  3. The authorized body determined that total compensation of $5,250 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.