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PeerBasis
Compensation Comparability Determination

Cottage Street Youth Law

Executive Director / CEO

EIN 880817327
OR · NTEE I80
FY ending 2024-12-31
June 9, 2026

This analysis benchmarks the total compensation of Dale Wilhelm, Executive Director / CEO ($102,200) against every comparable organization that fit the selection criteria — 62 in total — drawn systematically from IRS Form 990 filings, not a hand-picked subset.

Compensation sits at approximately the 81st percentile of comparable organizationswithin the typical range

Benchmarked executive: Dale Wilhelm — reported title “EXECUTIVE DIRECTOR”, a direct title match to the Executive Director / CEO role.

How comparable organizations were selected

62 organizations qualified on sector, size, and geography 62 within the band form the benchmarked peer set.

Distribution of comparable compensation

$11 total compensation of comparable organizations → $438,085 $102,200
$26,29810th
$41,06025th
$67,482Median
$97,54175th
$134,25390th
$102,200This org · 81st
p10$26,298
p25$41,060
p50$67,482
p75$97,541
p90$134,253
$102,200

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 OR 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
Inland Empire Latino Lawyers CA$239,060 Executive Director $84,635 $78,697 2024
Casa Of Berks County PA$238,542 Executive Di $53,297 $57,233 2024
The Rise Foundation By Envoy Inc IL$250,000 President And Executive Directo $132,563 $144,483 2023
Opening Doors International Services Inc TX$251,057 Executive Dir. $55,000 $59,244 2024
Crossroads For Florida Kids Inc FL$228,940 Executive Director $105,000 $106,217 2024
Pikes Peak Justice & Pro Bono Center CO$255,069 Executive Director $74,255 $76,672 2024
New Covenant Legal Services MO$256,169 Executive Di $60,000 $68,431 2024
Lex Mundi Pro Bono Foundation DC$257,339 Managing Dir $132,000 $124,733 2024
Great Lakes Expungement Network MI$258,107 Executive Director $40,516 $45,032 2024
Apoyo Legal Migrante Asociado CA$223,565 President $41,798 $40,014 2023
Canadian County Casa Inc OK$221,936 Exec Director $67,667 $78,167 2025
Florida Justice Center Inc FL$221,688 Executive Director $50,401 $50,985 2024
Phoenix Legal Action Network AZ$261,916 Executive Director $81,222 $86,599 2023
Legal Services Clinic Of The Puerto Rican Community Inc FL$220,815 President $39,000 $40,618 2023
4 The Children CO$219,757 Executive Director $57,589 $61,220 2023
Oregon Health Justice Center OR$263,336 Attorney/partner $105,769 $105,769 2024
El Centro Hispanoamericano NJ$264,706 Executive Director $49,660 $47,745 2024
Redirections Of Rockingham County NC$216,870 Executive Director $37,000 $42,384 2023
Wyoming County - Attica Legal Aid NY$267,246 Vice Preside $31,756 $30,103 2025
Allegany Law Foundation Inc MD$268,405 Executive Director $57,073 $59,154 2023
Frontline Legal Services LA$268,828 Co-executive Director $75,000 $88,930 2024
Equal Citizens Foundation DC$269,229 Treasurer $36,000 $34,018 2024
Education Law Association PA$212,035 Executive Di $77,610 $85,802 2023
Disability Legal Services Of Indiana IN$209,446 Executive Director $79,163 $89,896 2024
Open Immigration Legal Services Inc CA$208,729 President $59,013 $54,873 2024

Comp (reported) is the figure on each organization's Form 990 (columns D + F); Comp (adjusted) normalizes it to OR 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 OR 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 default81st
Total compensation (D + F), as reported (no adjustments)82nd
Reportable pay only (column D), adjusted60th
All sources (D + E + F), adjusted76th

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 (Dale Wilhelm) 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 62 similarly situated organizations (Same NTEE sector (I80), nationwide + budget 0.67–1.5× revenue).
  3. The authorized body determined that total compensation of $102,200 is reasonable (approximately the 81st 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.