Common Noninterest Income Tagging Errors

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Common Noninterest Income Tagging Errors

Bank holding companies ("BHCs") typically have certain noninterest income, such as net interchange fees earned on credit or debit transactions and trust and wealth management fees, that falls within the scope of Topic 606 - Revenue from Contracts with Customers. Staff in the Commission's Division of Economic and Risk Analysis have completed an assessment of BHCs' tagging practice for noninterest income in Forms 10-K for the fiscal year ended 2025.

Staff have observed the following common tagging issues related to noninterest income:

• Inappropriate use of custom element to tag noninterest income line items within the scope of Topic 606. The appropriate approach is to use either us-gaap:RevenueFromContractWithCustomerIncludingAssessedTax or us-gaap:RevenueFromContractWithCustomerExcludingAssessedTax, as applicable, in conjunction with Product and Service [Axis] and an appropriate custom member.
• Inconsistent application of tags between noninterest income line items that are presented on the income statement and those disclosed in the note. For instance, certain banks tagged the in- scope noninterest income line items on the income statement with custom concepts. However, identical items-having the same description and amount-in the note disclosure, were tagged with standard us-gaap:RevenueFromContractWithCustomerExcludingAssessedtax, along with Product and Service [Axis] and custom members. Tagging should be consistent across both presentations.
• For the total noninterest income disclosed in a note that does not fall in the scope of Topic 606, either a custom element or the standard us-gaap:RevenueNotFromContractWithCustomer was used. In these cases, filers should use the standard us-gaap: RevenueNotFromContractWithCustomerExcludingInterestIncome element.

The Financial Accounting Standards Board's Generally Accepted Accounting Principles Taxonomy Implementation Guide Series - Revenue from Contracts with Customers (Including Statement Presentation of Revenue and Cost of Revenue) (2023), particularly examples 13a and 13b, provide examples of the revenue tagging for financial institutions. Filers are encouraged to review their tagging on noninterest income and make necessary corrections. For more data quality reminders, see Staff Observations and Guidance.

Last Reviewed or Updated: May 14, 2026