Sterling Compensation Analytics

Honor Your Executives.
Protect Your Board.

The Rebuttable Presumption of Reasonableness, IRC Section 4958, and How Proper Documentation Protects Board Members

By the Numbers
1.3M+
Executive comp records in our dataset
102,915
Unique tax-exempt organizations
18,241
Boards without a formal process
100%
IRS-compliant primary source data

Setting Compensation
with Intention

People who serve on nonprofit boards bring something rare to the table: a genuine commitment to purpose over profit. They give their expertise, their judgment, and their time to organizations that exist to serve communities, advance knowledge, support the arts, and strengthen the social fabric. It is meaningful work, and it deserves to be taken seriously.

Honoring the executives who dedicate their careers to that mission begins with compensation. To pay an executive fairly — and to know with confidence that you have done so — is an act of respect for the work itself. It signals that the board has done its homework, that it takes its fiduciary responsibility seriously, and that it values the people entrusted to carry the organization forward.

A well-run compensation process does more than satisfy a requirement. It produces a decision the entire board can stand behind — one that can be explained to any donor, auditor, or regulator who asks. It documents the board's reasoning at the moment of the decision, in a form that demonstrates exactly the kind of careful, deliberate governance that distinguishes exceptional organizations.

Sterling Compensation Analytics exists to make that process accessible. We bring the data, the methodology, and the documentation infrastructure that nonprofit boards need to set compensation with intention — and with confidence. Our clients don't work with us because they have to. They work with us because they understand that doing this right is a reflection of who they are.

The law rewards exactly this approach. IRC Section 4958 provides a safe harbor — the rebuttable presumption of reasonableness — that protects board members who follow a documented process. Three specific conditions must be satisfied.
1
Independent Approval
Compensation is approved in advance by an authorized body composed entirely of individuals without a conflict of interest. The affected executive is recused from deliberations and the vote.
2
Appropriate Comparability Data
The authorized body obtains and relies upon compensation data from similarly situated organizations for functionally comparable positions — filtered by revenue, mission, and geography. This is the condition most commonly handled inadequately, and the one Sterling directly satisfies.
3
Concurrent Documentation
The basis for the determination is documented in board minutes or a written resolution at the time of the decision — not reconstructed after the fact.

Sterling delivers a single board-ready report designed to satisfy all three conditions.

Board meeting in session
Deliberate governance begins with the right process — and the right data.

Primary Source Data,
Not Third-Party Summaries

1.3M+Executive Comp
Records
102,915Unique Tax-Exempt
Organizations
12Executive
Titles Covered
100%IRS-Compliant
Primary Source

The typical compensation committee member knows of perhaps a few hundred comparable organizations. Sterling draws on 1.3 million records.

Our benchmarks are derived entirely from IRS-compliant primary source filings — not third-party surveys, not aggregated indices, not self-reported data. Every figure reflects what an organization actually disclosed under penalty of perjury, covering more than 102,000 unique tax-exempt organizations.

Because all compensation data reflects filings from prior years, Sterling applies a proprietary model that controls for the systematic relationship between compensation and organizational characteristics — producing benchmarks that are materially more current than any published salary survey.

Boardroom
Data Scale
Sterling Compensation Analytics
1.3M+ records
Typical salary survey
~50K records

What the Report Delivers

Each Sterling benchmark report satisfies all three rebuttable presumption conditions in a single board-ready document.

Peer Group Construction
Revenue band, mission category, and geography — tailored to the specific organization and role.
Percentile Table
10th through 90th percentile across the peer group for the relevant executive title.
Regression-Derived Point Estimate
Confidence interval included — defensible to the IRS and to counsel.
Compensation Trend Analysis
Year-over-year market movement to demonstrate currency of the data.
§4958 Compliance Checklist
Confirms satisfaction of all three rebuttable presumption conditions.
Board Minutes Attachment
Signature-ready page formatted for direct attachment to board minutes.

Sterling's Six-Step Engagement

Sterling walks you through each condition step by step — so the board is protected and the documentation holds up.

1
Understand
the Need
Governance context
Org profile
Comp history
2
Gather
Details
Institution-specific data
Executive role scope
Peer criteria
3
Analysis
Peer group construction
Percentile table
Regression model
4
Executive
Review
Senior Sterling review
Findings validated
Report finalized
5
Presentation
Board-ready PDF
Minutes attachment
Checklist included
6
Meeting*
Sterling attends board
Live presentation
*If selected by client

What Our Clients Say

I haven't found anybody better in my 40 years than the people I strategized with at Sterling.

Bruce Popper
Bruce Popper
Financial Advisor, Lion Street Private Client Group
What struck me was Sterling's ability to connect with me as an individual. I was already sold before I started.

Barbara Bollard
Barbara Bollard
Client
We found the firm absolutely first class and excellent in our dealings. We can certainly commend the firm to those who wish to consider long-term planning.

Bruce Garratt
Bruce Garratt
Client

Sterling's Leadership Team

Deep expertise in nonprofit governance, tax-exempt compensation law, and advanced data analytics.

James W. Lintott
James W. Lintott, Esq.
Founder & Chairman
Stanford
Roger D. Silk
Roger D. Silk, Ph.D.
Founder & CEO
Stanford
Paul Beckner
Paul Beckner
Principal
Wharton MBA
Giovanni Kotoriy
Giovanni (Gio) Kotoriy
Vice President
Notre Dame & PWC
Katherine Silk
Katherine Silk
Director of Trust Services
Stanford
Henry Ginna
Henry Ginna
Senior Client Services Officer
Yale

Receive the Whitepaper

Fill out the form below and we'll send you our white paper: Executive Compensation: Best Practices for Nonprofit Boards — covering the rebuttable presumption standard, IRC Section 4958, and how Sterling helps boards set compensation with confidence.

Sterling does not share your information with third parties. By submitting this form you may be contacted by a Sterling advisor.
Questions? Email henry.ginna@sterlingfoundations.com

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Be an Effective Leader.
Bring Best Practice to Your Board.

Sterling Compensation Analytics gives you the tools to fulfill your governance responsibilities correctly — with current-year benchmarks, a rigorous methodology, and documentation that demonstrates exactly the kind of informed, deliberate governance the law respects.

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