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PeerBasis
Compensation Comparability Determination

Benevolent & Protective Order Of Elks

Executive Director / CEO

EIN 950540960
CA · NTEE Y40
FY ending 2024-03-31
June 9, 2026

This analysis benchmarks the total compensation of David Wafford, Executive Director / CEO ($750) against every comparable organization that fit the selection criteria — 37 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

How comparable organizations were selected

37 organizations qualified on sector, size, and geography 37 within the band form the benchmarked peer set.

Distribution of comparable compensation

$735 total compensation of comparable organizations → $112,049 $750
$4,27810th
$5,01225th
$7,477Median
$20,34175th
$27,32490th
$750This org · 3rd
p10$4,278
p25$5,012
p50$7,477
p75$20,341
p90$27,324
$750

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.

OrganizationStateTotal revenueTotal compSource
Putnam Lodge Of Elks #574CT $336,541$4,231 990
Fraternal Order Of EaglesWA $341,334$11,850 990
Colonial Heights Moose Lodge 1783VA $342,540$26,907 990
Benevolent & Protective Order Of ElksOH $321,435$11,315 990
Masonic Charity FoundationNM $316,334$11,287 990
Benevolent & Protective Order OfCT $353,017$8,687 990
Independence Fraternal Order Of Police LMO $303,742$5,180 990
Fraternal Order Of Eagles 162AK $365,797$6,678 990
Fraternal Order Of EaglesNE $301,594$7,477 990
Tuskegee Airmen IncAL $298,886$51,522 990
Bpo Elks Lockport NyNY $291,426$4,529 990
Grand Chapter Of Tennessee Order OfTN $287,028$14,231 990
International Association OfNC $384,320$24,929 990
Benevolent And Protective Order OfMO $281,304$7,016 990
St Joseph Aerie No 49 Fraternal Order Of EaglesMO $273,020$4,310 990
Bozrah Lodge No 950 Loyal Order Of MooseCT $270,097$32,370 990
Benevolent And Protective Order OfNJ $269,966$5,012 990
Rhode Island Masonic Youth FoundationRI $269,401$25,287 990
Benevolent & Protective Order Of Elks Rotterdam #2157NY $399,547$5,301 990
Benevolent & Protective Order Of Elks #2166FL $267,615$7,420 990
Fraternal Order Of Police -MD $263,341$25,414 990
Benevolent & Protective Order Of Elks Lodge 1106PA $262,556$5,288 990
Benevolent & Protective Order OfOH $408,917$4,780 990
New York Veteran Police Association IncNY $415,313$20,341 990
Nanticoke Aerie No 834 Fraternal Order Of EaglesPA $248,010$21,908 990

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 default3rd
Total compensation (D + F), as reported (no adjustments)3rd
Reportable pay only (column D), adjusted3rd
All sources (D + E + F), adjusted3rd

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 (David Wafford) 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 37 similarly situated organizations (Same NTEE sector (Y40), nationwide + budget 0.67–1.5× revenue).
  3. The authorized body determined that total compensation of $750 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). 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.