Your board gets a report every quarter that benchmarks the bank against its peers on capital, asset quality, earnings, liquidity, interest rate risk, and credit concentration.

It does not benchmark your card program. Not one line of it.

The Uniform Bank Performance Report is the FFIEC's standard peer comparison — the one examiners work from. Page 3 covers noninterest income, and it splits that income into nine categories:

Fiduciary activities. Service charges on deposit accounts. Trading revenue. Investment banking and brokerage. Insurance commissions. Net servicing fees. Gains on sales of loans. Gains on sales of other assets. And "other noninterest income."

Debit interchange lands in that last one. So do ATM fees. So does most of what a card program earns.

It isn't hidden. It's just not broken out — which means there's no peer ratio for it, no trend line, and nothing for a director to compare against anything.

Sit with what that means. Deposit service charges get benchmarked against peers every quarter. Fiduciary income gets benchmarked. Insurance commissions get benchmarked.

The card program gets measured by nobody except the processor that runs it.

I don't think that's a scandal. I think it's an artifact of a report built for a different era, and nobody has gone back to fix it.

But it explains something I run into a lot. When I ask a bank executive how their debit yield compares to similar banks, the most common answer is "I don't know" — and that isn't inattention. It's that the report which answers that question for everything else doesn't answer it for this.

How big is that line at your bank? It's a fair question, and you can answer it. It just won't come from the UBPR.

Source: FFIEC Uniform Bank Performance Report User's Guide, "Noninterest Income and Expenses — Page 3". On the Call Report side, Schedule RI-E is where "other noninterest income" gets itemized — "bank card and credit card interchange fees" and "income and fees from ATMs" are two of its preprinted lines.