Compensation Review Policy (Doc 09)

Purpose

Define compensation governance for Executive Director, officers, and key employees using IRS rebuttable presumption controls.

Required Elements

1. Independent authorized approval body
2. Appropriate comparability data
3. Contemporaneous written documentation

Annual + Mid-Cycle Reviews

• annual review required and aligned to budget/fiscal cycle
• mid-cycle adjustments allowed with full controls
• ED self-initiated review request must be submitted in writing to Board Chair, who convenes independent review

Excess Benefit Prevention

Potential excess benefit cases are escalated for corrective action and counsel review.

Note for legal review: Excess benefit transactions under IRC 4958 may carry excise tax exposure on the disqualified person. Counsel should determine whether explicit statutory citation should remain in-policy or in separate legal guidance.

Board Member Compensation

Any board-member compensation action requires disinterested review and documented reasonableness determination.

Note for legal review: Confirm whether Florida nonprofit law imposes additional constraints on director compensation beyond bylaws provisions.