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PeerBasis
Compensation Comparability Determination

Sheet Metal Workers Local 104

Executive Director / CEO

EIN 946138707
CA · NTEE J220
FY ending 2023-12-31
June 9, 2026

This analysis benchmarks the total compensation of Ben Rivera, Executive Director / CEO ($329,800) against every comparable organization that fit the selection criteria — 31 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: Ben Rivera — reported title “CO-ADMINISTRATORS”, selected as the organization's highest-paid individual — no exact title match, so confirm this is a comparable role.

How comparable organizations were selected

31 organizations qualified on sector, size, and geography 31 within the band form the benchmarked peer set.

Distribution of comparable compensation

$16,560 total compensation of comparable organizations → $501,311 $329,800
$112,20210th
$157,71325th
$241,401Median
$310,56475th
$390,36290th
$329,800This org · 81st
p10$112,202
p25$157,713
p50$241,401
p75$310,564
p90$390,362
$329,800

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 CA 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
Aws Foundation Incorporated FL$11,713,709 Executive Director, Foundation $15,222 $16,560 2023
Operating Engineers Local No 825 NJ$11,742,750 Director Of Training $269,021 $278,161 2023
New York State Lineman's Safety NY$11,601,029 Safety Direc $311,576 $308,537 2025
Community Action Board CA$11,538,769 Executive Dir. $248,531 $241,401 2024
Uaw- Labor Employment And Training Corp CA$12,343,170 President And Chairman $321,823 $312,590 2024
🔒 26 more comparable organizations — included in the purchased report

Comp (reported) is the figure on each organization's Form 990 (columns D + F); Comp (adjusted) normalizes it to CA 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 CA 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)84th
Reportable pay only (column D), adjusted45th
All sources (D + E + F), adjusted81st

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:

Ready-to-adopt board minutes — executive compensation

🔒 The complete minutes language — three numbered resolutions pre-filled with this organization, the 31-organization comparison, the date, and the percentile finding, ready to paste into your minutes — is included in the purchased report.

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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.