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PeerBasis
Compensation Comparability Determination

United Steelworkers Local 11-13214

Executive Director / CEO

EIN 830181990
WY · NTEE S40
FY ending 2024-12-31
June 9, 2026

This analysis benchmarks the total compensation of Marshal Cummings, Executive Director / CEO ($37,637) against every comparable organization that fit the selection criteria — 94 in total — drawn systematically from IRS Form 990 filings, not a hand-picked subset.

Compensation sits at approximately the 7th percentile of comparable organizationsbelow the typical range for comparable organizations

Benchmarked executive: Marshal Cummings — reported title “President”, a direct title match to the Executive Director / CEO role.

How comparable organizations were selected

94 organizations qualified on sector, size, and geography 94 within the band form the benchmarked peer set.

Distribution of comparable compensation

$18,701 total compensation of comparable organizations → $1,066,194 $37,637
$39,70110th
$64,95325th
$97,016Median
$158,14975th
$216,94190th
$37,637This org · 7th
p10$39,701
p25$64,953
p50$97,016
p75$158,149
p90$216,941
$37,637

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 WY 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
Int'l Ind Showmen's Foundation Inc FL$469,399 Director $38,295 $34,588 2023
Air Refueling Systems Advisory Group International TX$468,559 Chairman $66,539 $63,993 2023
Utah Ready Mixed Concrete Association UT$476,463 Executive Director $212,082 $202,706 2024
Us Coalition On Sustainability CT$477,294 Executive Director $160,000 $144,235 2023
Walworth County Economic Development WI$478,791 Executive Director $113,777 $110,966 2024
Volta Foundation Inc CA$460,846 Executive Director $70,000 $58,115 2023
Rhode Island Assisted Living Association RI$481,607 Executive Director $83,673 $74,926 2024
Oregon Veterinary Medical Association OR$454,880 Ex Dir/treasure $89,977 $80,337 2023
P20 Inc GA$487,479 President $194,400 $182,539 2024
New Hampshire Life Sciences Inc NH$488,138 President & $98,500 $84,936 2024
Pennsylvania Outdoor Recreation PA$490,884 Executive Director $64,910 $58,891 2025
Darien Mcintosh County Chamber GA$491,626 Executive Director $50,000 $46,949 2024
Society Of Product Licensors Committed To Excellence NY$495,782 Chief Executive $199,061 $172,943 2023
Business Leadership Council IL$445,387 Executive Director $94,792 $89,599 2023
Commuter Rail Coalition VA$443,067 Ceo $200,000 $193,276 2022
Wyoming Capital Access WY$440,118 President $66,375 $66,375 2024
German American Business Council Inc DC$438,038 President/ceo $354,000 $298,670 2023
Greater Leimert Park Village & Crenshaw CA$437,333 Executive Dir. $60,000 $49,813 2023
Routt County Economic Development CO$436,373 Executive Dir. $99,225 $88,852 2024
Indo Am Chamber Of Commerce Of Greater Dallas TX$434,330 Executive Director $115,000 $107,428 2024
Tech Serve International Inc AR$428,555 President $92,928 $97,548 2024
Battle Creek Area Assoc Of Realtors MI$427,595 Ceo $76,351 $75,769 2023
Business Network Of Emergency Resources NY$427,009 President / Ceo $90,000 $75,948 2024
Shelby County Tourism & Visitors' IN$422,361 Executive Di $62,875 $61,920 2024
R Street Sacramento Partnership CA$420,086 Administrator $52,920 $42,674 2024

Comp (reported) is the figure on each organization's Form 990 (columns D + F); Comp (adjusted) normalizes it to WY 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 WY 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 default7th
Total compensation (D + F), as reported (no adjustments)5th
Reportable pay only (column D), adjusted10th
All sources (D + E + F), adjusted4th

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 (Marshal Cummings) 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 94 similarly situated organizations (Same NTEE sector (S40), nationwide + budget 0.67–1.5× revenue).
  3. The authorized body determined that total compensation of $37,637 is reasonable (approximately the 7th 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.