--- title: "Why We Built BankRegReports: The Bank Data Problem" description: "BankRegReports gives community bankers clean peer benchmarks from FFIEC, FDIC, and Fed data: no vendor contract, no data engineering, ALCO-ready." canonical_url: https://www.bankregreports.com/blog/why-we-built-bankregreports/ source: BankRegReports published: "2026-10-21" updated: "2026-10-22" --- ## The Peer Data Problem Inside Every ALCO Package Picture a Wednesday afternoon before the board ALCO meeting. Your treasurer pulls the NIM trend from one source. The CFO has deposit cost comparisons from the FDIC's public tools. The chief credit officer is working from last quarter's examiner ROE, which cited a peer NIM of 3.41%, different from both of those. Nobody is wrong. They are all looking at the same public data through different windows, and the windows do not line up. This is the problem [BankRegReports](https://www.bankregreports.com) was built to fix. Not for data scientists. For CFOs, treasurers, credit officers, and examiners, people who need peer benchmarks they can defend in a board presentation or a regulatory examination without spending three days reconciling spreadsheets first.
Net interest margin by bank asset-size band, 2002 to 2025
The peer-data problem in one chart: net interest margin diverges by bank size over 2002–2025, so a community bank compared to the industry average is compared to the wrong bank. BankRegReports analysis.
## Why Is Public Data Harder Than It Should Be? Every quarter, every FDIC-insured bank files a Call Report. Larger bank holding companies file the [FR Y-9C](/blog/what-is-the-fr-y-9c/). The FFIEC publishes [UBPR ratios](/blog/how-to-read-ubpr-report/), the same derived performance metrics your examiners use when they sit across the table from you. The Federal Reserve, FDIC, and NCUA publish all of it. It is public record by design, and the official source for the Call Report and UBPR is the [FFIEC](https://www.ffiec.gov). The practical problem is that "public" does not mean "clean" or "consistent." The FFIEC Call Report alone spans dozens of schedules (RC, RC-B, RC-C, RC-E, RC-K, RC-N, RI, RI-B), each with its own structure. A concept as straightforward as "total loans" traces back to different [MDRM item codes](/blog/mdrm-codes-developer-guide/) depending on the filing period, the charter type, and whether you are looking at the bank or the consolidated holding company. Item codes change when regulatory guidance evolves. Predecessor codes retire. A ratio that was directly comparable across institutions in 2019 may require adjustment by 2023 because the definition shifted. The UBPR adds another layer of complexity. The FFIEC computes UBPR ratios from raw Call Report data, but the formula definitions reference MDRM codes that map differently for thrift filers versus commercial bank filers. If you want to reproduce a UBPR ratio from source data (which sometimes you have to, when you need a metric the UBPR does not publish), you need the formula documentation, the code history, and enough institutional knowledge to know what changed and when. Then there is the question of holding company versus bank-level data, NCUA 5300 forms for credit unions, SEC EDGAR disclosures for publicly traded institutions, and Federal Reserve NIC records for entity relationships. Each source has its own schema and update cadence, which is why [the same bank can show different numbers in different sources](/blog/cross-source-bank-data-reconciliation/). Enterprise vendors have normalized all of this into polished platforms. Their licenses are priced for institutional budgets, and per-seat licensing makes it impractical for a community bank's three-person finance department or a consulting firm running peer analyses for mid-size clients. For the institutions and teams that most need clean comparative data (the ones without dedicated data infrastructure and enterprise vendor budgets), the economics have never worked. ![Community Bank NIM vs. Large Bank NIM, Q2 2026](figures/why-we-built-bankregreports-1.svg) ## What the BankRegReports Platform Actually Delivers [BankRegReports](https://www.bankregreports.com) is a web platform built for practitioners who already understand the regulatory framework. You log in, search for your institution or define a peer group by asset tier and charter type, and get clean, sourced data, the same metrics your examiners reference, with the formula documentation to back them up. The platform covers six source systems that matter to community bankers: **FFIEC Call Reports** at the schedule-item level, with full filing history and MDRM code transitions handled across periods. The granularity is the same as what examiners pull when they prepare their ROE. **UBPR performance ratios** in the same data layer as the raw Call Report data. Having both together means you can cross-validate your internal calculations against the FFIEC's own derived ratios, and close the gap when your numbers differ from the examiner's. **FDIC institution records** for the entity master: charter type, state, primary regulator, asset size history, and merger history. This is where peer group filtering by charter class and asset tier comes from. **Federal Reserve NIC and Y-9C** for the holding company layer. NIC provides the ownership structure: which bank is controlled by which bank holding company or mutual holding company. Y-9C provides consolidated holding company financials. Any analysis that needs to move between the bank level and the holding company level depends on these two sources. **NCUA 5300** data treated as a first-class source, not an afterthought. The credit union equivalent of the FFIEC Call Report, with the same analytical framework applied consistently. **SEC EDGAR** for publicly traded bank holding companies: 10-K and 10-Q filings that connect regulatory capital ratios to public financial disclosures in the same platform. Every metric in the platform traces back to its source filing and the formula used to compute it. When a number differs from what your examiner cited, you can identify why (definitional difference, peer group composition, filing amendment) rather than defending a black box. ![Efficiency Ratio Distribution - Community Banks $300M-$10B, Q2 2026](figures/why-we-built-bankregreports-2.svg) ## The Benchmarks That Matter Right Now Community banks in the $1B–$10B asset range are working through a specific set of pressures in 2025 that make peer data more valuable, and more contested, than it has been in years. The median NIM for $1B–$10B banks fell from 3.57% at the end of 2022 to 3.07% in March 2024 as deposit repricing caught up, and was 3.34% at March 31, 2025. Institutions that locked in longer-duration liabilities at cycle lows are now repricing at higher rates, while the asset side faces prepayment and rollover dynamics that vary significantly by loan mix. The spread between the top and bottom quartile of NIM performance across community banks has widened; knowing where your institution sits in that distribution, and why, is the kind of context an ALCO package needs. On capital, the median CET1 ratio for $1B–$10B banks was 13.2% at March 31, 2025, well above the 6.5% well-capitalized threshold, but the buffer is uneven. Institutions that grew aggressively during the 2020–2021 liquidity surge absorbed significant credit risk, and some are now watching capital ratios under pressure from unrealized loss positions in their securities portfolios. The practical floor for a community bank that wants to avoid examiner capital adequacy questions is typically 10–11% CET1, with anything below 10% requiring a credible capital plan. Asset quality metrics are normalizing off historically low levels. The median noncurrent loan ratio for $1B–$10B banks fell from 0.35% at the end of 2021 to 0.27% at the end of 2022, then climbed to 0.43% at March 31, 2025 and 0.52% at June 30, 2026 (BankRegReports analysis of Call Report data): still low by historical standards, but moving the other way. Charge-offs have moved off their 2021 lows too; the FDIC Quarterly Banking Profile put community bank net charge-offs at 0.15% annualized in Q1 2025, against 0.67% for the industry. What matters for the board conversation is not just the current level but the trajectory relative to peers, and whether specific loan categories (office CRE, construction, consumer) are driving disproportionate movement. [CRE concentration](/blog/cre-concentration-risk-banks/) remains a standing examiner topic. The interagency guidance screens (total CRE at 300% of risk-based capital with growth of 50% or more over the prior 36 months, construction and land development at 100%) are not limits and have not changed, but examiner scrutiny of institutions above those thresholds has intensified as the office and multifamily sectors work through stress. Institutions that meet those screens need to demonstrate that their concentration management framework (stress testing, underwriting standards, portfolio monitoring) matches the risk they are carrying. ## The Access Gap This Platform Closes The teams that pull the most value from BankRegReports are the ones who have spent time on the wrong side of this access gap: community bank CFOs and treasurers who need peer benchmarks for board packages but cannot justify an enterprise vendor contract, credit officers who need portfolio composition comparisons across peer institutions for concentration management presentations, bank consultants running peer analyses across dozens of clients without per-seat licensing that makes the economics unworkable, and examiners and researchers who need the underlying filing data rather than a pre-packaged dashboard. You can pull peer group comparisons directly from the [BankRegReports platform](https://www.bankregreports.com), export to Excel, and have the data your ALCO package needs without reconciling multiple data sources or explaining to your board why your NIM trend differs from the examiner's. The methodology behind every metric is published, not because transparency is a marketing point, but because the people who use this data professionally need to know what they are looking at when the numbers do not match. The pricing is designed for teams without enterprise data budgets. That is a deliberate choice. The underlying data is public record. The value is in the normalization, the documentation, and the access layer, and that should be priced in a way that makes it available to the institutions that most need it, not just the ones with the procurement budgets to afford the incumbents. If your last ALCO cycle included a conversation about whose peer data was right, or your last examination produced a finding where the examiner's numbers differed from yours and nobody could say why, that is the problem this platform was built to solve. A [bank peer group analysis](/blog/bank-peer-group-analysis/) is a good first test: build one, then check whether you can explain every number in it. --- The benchmarks and peer data referenced in this post are available through the [BankRegReports platform](https://www.bankregreports.com), no data engineering required. Search any FDIC-insured bank, pull peer group comparisons, and, on the Pro plan, export to Excel for your ALCO package or board presentation. ## About this document This is the markdown twin of the page named in `canonical_url` above. Source filings are public record; the cleaning, normalization, cross-source linkage, and derived metrics are BankRegReports' own. Attribute with a link to the canonical URL. Markdown twins are published for editorial content only. Institution data pages do not have them. For data at scale use the API, which is documented at https://www.bankregreports.com/api/ and specified at https://www.bankregreports.com/openapi.json. It returns typed JSON with explicit units and periods, and one call replaces hundreds of page fetches. ## Sitemap - [Glossary](https://www.bankregreports.com/glossary/): every metric, with formula and thresholds - [Blog](https://www.bankregreports.com/blog/): analysis and explainers - [API documentation](https://www.bankregreports.com/api/): the programmatic way to get this data - [XML sitemap](https://www.bankregreports.com/sitemap.xml): the complete crawlable index