Mars Hill's Compensation Process and ECFA Guidelines

Recently, Wenatchee the Hatchet posted a memo from Sutton Turner regarding Mark Driscoll’s salary recommendations. In the August 2012 memo, Turner wrote:

I would like to put forth a recommendation to raise Pastor Mark Driscoll’s salary to$650,000 for financial year 2013 based on the following:

Turner then made a case to the compensation committee for Driscoll to receive a substantial raise for FY 2013. He also indicated in the memo that he was the only person outside of the compensation committee who knew Driscoll’s salary.
I submit that Turner’s activity violated at least the spirit of the guidelines of the Evangelical Council for Financial Accountability. Regarding the setting of compensation, the ECFA guidelines state:

1. The board or an authorized committee of the board shall make the decision regarding total compensation, and those participating in the decision-making process may not have any conflict of interest in the decision, whether direct or indirect. That is, no person in the decision-making process may:
a. be related to the person whose compensation is being addressed,
b. be subordinate to the person whose compensation is being set,
c. be a person whose compensation is determined in a manner that involves input or decision-making by the person whose compensation is being set, or
d. otherwise have a conflict of interest.

Determining the extent of the violation hinges on a definition of “decision making process.” It could be argued that Turner had no part in the decision and therefore did not violate the guidance. I would argue however that recommendation and advocacy to the compensation committee was a conflict of interest for Turner who served at Driscoll’s pleasure. Information gathering is part of the decision making process and should be done by the compensation committee. Turner had intimate knowledge of the process, participated in it, and was the only staff person who knew the facts. If the ECFA guidance permits this kind of participation, then the value of the guidance is again called into question.
One could also argue that this memo was written before Mars Hill was accredited. However, did the process continue over the remainder of Driscoll’s time at Mars Hill? If so, it seems to me that the ECFA should at least investigate the role of subordinates in the setting of compensation for FY 2014 and the current year which most likely forms the basis for Driscoll’s severance package.