For board members and the advisers they ask
Asked for comparables? Start with named peers, then the percentile.
A comparables request has a shape. First, a list of named organizations of similar size and mission and what each one reported paying. Second, where the figure under review sits among those peers, and only then where it sits in a percentile band. Third, the record the regulation asks your minutes to show. This page walks that order with the same illustrative sample the sample board report is built from.
CauseComp provides comparability data and does not provide legal or tax advice.
First
The named peer set
Each row is one organization, its most recent filing year, the title it reported and the total compensation it reported for that position, projected to December 31, 2026 as in the sample report. Ranked by projected total compensation. The highlighted row is the figure under review, placed where it falls.
Illustrative sample. Fictional organizations, invented figures. Not a benchmark.| Organization | Location | FY | Title | Revenue | Total comp |
|---|---|---|---|---|---|
| Harbor Light Community Trust | Portland, OR | 2024 | President & CEO | $9,800,000 | $227,990 |
| Northfield Care Alliance | Gresham, OR | 2025 | President & CEO | $9,100,000 | $224,732 |
| Emberline Community Works | Hillsboro, OR | 2024 | Executive Director | $8,400,000 | $220,822 |
| Silverbrook Youth Alliance | Tigard, OR | 2024 | Chief Executive Officer | $7,700,000 | $218,634 |
| Willamette Bridge Collective | Eugene, OR | 2025 | Chief Executive Officer | $7,300,000 | $196,562 |
| The figure under review (Northgate Harbor Alliance, sample) | $195,016 | ||||
| Quarry Hill Neighbor Trust | Beaverton, OR | 2024 | Executive Director | $6,900,000 | $194,210 |
| Cascade Meadow Outreach | Medford, OR | 2024 | Executive Director | $6,200,000 | $192,759 |
| Cobblewood Neighbor Trust | La Grande, OR | 2024 | Chief Executive Officer | $7,100,000 | $186,261 |
| Broadleaf Family Partners | McMinnville, OR | 2025 | Executive Director | $6,600,000 | $181,386 |
| Cedar Point Family Services | Salem, OR | 2025 | Executive Director | $5,100,000 | $181,067 |
| Fernhollow Housing Partners | Corvallis, OR | 2025 | Executive Director | $5,600,000 | $175,149 |
| Alder Grove Family Center | Albany, OR | 2025 | Executive Director | $5,200,000 | $151,632 |
| Three Rivers Neighbor Fund | Bend, OR | 2025 | Executive Director | $4,700,000 | $151,088 |
| Marrowstone Community Fund | Pendleton, OR | 2025 | Executive Director | $5,800,000 | $149,459 |
| Two Creeks Support Network | Springfield, OR | 2025 | Executive Director | $4,300,000 | $146,961 |
| Rockford Bend Assistance League | Ontario, OR | 2024 | Executive Director | $4,900,000 | $139,140 |
| Sandpiper Youth Coalition | Astoria, OR | 2025 | Chief Executive Officer | $3,900,000 | $136,099 |
| Halloway Street Services | The Dalles, OR | 2025 | Executive Director | $4,400,000 | $135,026 |
| Wayfarer Community Services | Roseburg, OR | 2025 | Executive Director | $4,100,000 | $132,427 |
| Pinewater Outreach Group | Klamath Falls, OR | 2025 | Executive Director | $3,600,000 | $128,713 |
20 organizations, the same roster as the sample board report. A subscriber's set is drawn from public Form 990 filings for the role entered (or, if the subscriber chooses, from Executive Director / CEO filings), within one-third to three times the budget size entered, from each organization's own three most recent filing years among organizations that have filed in the last five years, and by default it favors organizations in the sector and state entered.
Documented comparability data like the above supports — but does not by itself establish — a board's rebuttable presumption of reasonableness under IRC §4958 (intermediate sanctions). The presumption also requires advance approval by an independent board body and contemporaneous documentation. CauseComp provides comparability data for informational purposes and does not provide legal or tax advice.
Second
Where the figure sits among the named peers, then in the percentile band
The figure under review in this sample is $195,016, the sample report's modeled median, so this page and the sample PDF show one number.
Among the named peers
$195,016 sits above 15 of the 20 named peers and below 5.
After the peers, the percentile band
The band is modeled from Form 990 filings for organizations like the one entered. The peer set is drawn separately and does not produce the band. A board sees both, and the minutes can cite both.
Third
The three conditions the regulation sets for the presumption
The rebuttable presumption has three conditions. A peer set and a percentile band are evidence for the second one. The first and the third are the board's to carry out and to record. The regulation, verbatim:
Payments under a compensation arrangement are presumed to be reasonable, and a transfer of property, or the right to use property, is presumed to be at fair market value, if the following conditions are satisfied: (1) The compensation arrangement or the terms of the property transfer are approved in advance by an authorized body of the applicable tax-exempt organization (or an entity controlled by the organization within the meaning of 53.4958-4(a)(2)(ii)(B)) composed entirely of individuals who do not have a conflict of interest (within the meaning of paragraph (c)(1)(iii)) with respect to the compensation arrangement or property transfer, as described in paragraph (c)(1); (2) The authorized body obtained and relied upon appropriate data as to comparability prior to making its determination, as described in paragraph (c)(2); and (3) The authorized body adequately documented the basis for its determination concurrently with making that determination, as described in paragraph (c)(3).26 CFR 53.4958-6(a)
What the written record must note
For a decision to be documented adequately, the written or electronic records of the authorized body must note— (A) The terms of the transaction that was approved and the date it was approved; (B) The members of the authorized body who were present during debate on the transaction that was approved and those who voted on it; (C) The comparability data obtained and relied upon by the authorized body and how the data was obtained; and (D) Any actions taken with respect to consideration of the transaction by anyone who is otherwise a member of the authorized body but who had a conflict of interest with respect to the transaction.26 CFR 53.4958-6(c)(3)(i)
Read the plain-language guide to the rebuttable presumption and to documenting executive pay decisions.
Before the meeting: a short checklist
If your organization's annual gross receipts are under $1 million, the regulation sets a lower bar for the data: three comparable organizations in the same or similar communities for similar services.
Special rule for compensation paid by small organizations. For organizations with annual gross receipts (including contributions) of less than $1 million reviewing compensation arrangements, the authorized body will be considered to have appropriate data as to comparability if it has data on compensation paid by three comparable organizations in the same or similar communities for similar services.26 CFR 53.4958-6(c)(2)(ii)
The presumption has three parts. This document is evidence for the second one only. The first and third are the board's to carry out and record.
Payments under a compensation arrangement are presumed to be reasonable, and a transfer of property, or the right to use property, is presumed to be at fair market value, if the following conditions are satisfied: (1) The compensation arrangement or the terms of the property transfer are approved in advance by an authorized body of the applicable tax-exempt organization (or an entity controlled by the organization within the meaning of 53.4958-4(a)(2)(ii)(B)) composed entirely of individuals who do not have a conflict of interest (within the meaning of paragraph (c)(1)(iii)) with respect to the compensation arrangement or property transfer, as described in paragraph (c)(1); (2) The authorized body obtained and relied upon appropriate data as to comparability prior to making its determination, as described in paragraph (c)(2); and (3) The authorized body adequately documented the basis for its determination concurrently with making that determination, as described in paragraph (c)(3).26 CFR 53.4958-6(a)
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The options
Named peers or percentiles only: how the options compare
Every third-party figure below shows the page it was read from and the date it was read. CauseComp's own prices are served from its price catalog at page load.
| Option | What you get | Named peers | Price |
|---|---|---|---|
| CauseComp Board Report | One position. A named peer set of up to 20 organizations from public Form 990 filings, Schedule J pay components, the percentile band, and the regulation quoted on its own page. | Yes | $349 one-time Price catalog, served at page load |
| CauseComp Professional | Executive benchmarks, named peer sets and board reports across every role, plus workforce benchmarks and Excel export. | Yes | $996 per year Price catalog, served at page load |
| Candid Nonprofit Compensation Report | Aggregate percentiles for 14 leadership positions by budget size, location and cause area, one annual edition. | No | $449 single-userSource, read 2026-09-07$1,199 multi-userSource, read 2026-09-07 |
| Your state nonprofit association's survey, two examples | Survey aggregates by role and budget band for one state, priced by membership and by whether you took the survey. Two associations' published prices are shown; other states price their own. | No | Montana Nonprofit Association, $75 to $150Source, read 2026-09-07Utah Nonprofits Association, $125 to $250 (nonprofit tiers)Source, read 2026-09-07 |
Percentile-only sources are useful. They answer a different question from the one a board is asked to minute, which is which organizations were looked at and what each paid.
Need it for one position only? See the one-time Board Report.