All material revenue from contracts with customers in the scope of ASC 606 is recognized within noninterest income. The following table presents the Company’s noninterest income by revenue stream and reportable segment, net of eliminations, for the three and nine months ended September 30, 2019 and 2018.

(In Thousands of Dollars)	Trust Segment		Bank Segment		Totals
For Three Months Ended September 30, 2019
Service charges on deposit accounts	$	0	$	1,208	$	1,208
Debit card and EFT fees		0		935		935
Trust fees		1,905		0		1,905
Insurance agency commissions		0		681		681
Retirement plan consulting fees		338		0		338
Investment commissions		0		384		384
Other		0		1,990		1,990
Total noninterest income	$	2,243	$	5,198	$	7,441

(In Thousands of Dollars)	Trust Segment		Bank Segment		Totals
For Three Months Ended September 30, 2018
Service charges on deposit accounts	$	0	$	1,151	$	1,151
Debit card and EFT fees		0		814		814
Trust fees		1,827		0		1,827
Insurance agency commissions		0		567		567
Retirement plan consulting fees		470		0		470
Investment commissions		0		273		273
Other		0		1,376		1,376
Total noninterest income	$	2,297	$	4,181	$	6,478

(In Thousands of Dollars)	Trust Segment		Bank Segment		Totals
For Nine Months Ended September 30, 2019
Service charges on deposit accounts	$	0	$	3,375	$	3,375
Debit card and EFT fees		0		2,600		2,600
Trust fees		5,584		0		5,584
Insurance agency commissions		0		2,223		2,223
Retirement plan consulting fees		1,146		0		1,146
Investment commissions		0		971		971
Other		0		5,056		5,056
Total noninterest income	$	6,730	$	14,225	$	20,955

(In Thousands of Dollars)	Trust Segment		Bank Segment		Totals
For Nine Months Ended September 30, 2018
Service charges on deposit accounts	$	0	$	3,139	$	3,139
Debit card and EFT fees		0		2,490		2,490
Trust fees		5,374		0		5,374
Insurance agency commissions		0		1,979		1,979
Retirement plan consulting fees		1,314		0		1,314
Investment commissions		0		844		844
Other		0		3,654		3,654
Total noninterest income	$	6,688	$	12,106	$	18,794

Service charges on deposit accounts – The Company earns fees from its deposit customers for transaction-based, account maintenance, and overdraft services. Management reviewed the deposit account agreements, and determined that the agreements can be terminated at any time by either the Bank or the account holder. Transaction fees, such as balance transfers, wires and overdraft charges are settled the day the performance obligation is satisfied. The Bank’s monthly service charges and maintenance fees are for services provided to the customer on a monthly basis are considered a series of services that have the same pattern of transfer each month. The review of service charges assessed on deposit accounts, included the amount of variable consideration that is a part of the monthly charges. It was found that the waiver of service charges due to insufficient funds and dormant account fees is immaterial and would not require a change in the accounting treatment for these fees under the new revenue standards.

Debit Card Interchange Fees – Customers and the Bank have an account agreement and maintain deposit balances with the Bank. Customers use a bank issued debit card to purchase goods and services, and the Bank earns interchange fees on those transactions, typically a percentage of the sale amount of the transaction. The Bank records the amount due when it receives the settlement from the payment network. Payments from the payment network are received and recorded into income on a daily basis. There are no contingent debit card interchange fees recorded by the Company that could be subject to a clawback in future periods.

Trust fees – Services provided to Trust customers are a series of distinct services that have the same pattern of transfer each month. Fees for trust accounts are billed and drafted from trust accounts monthly. The Company records these fees on the income statement on a monthly basis. Fees are assessed based on the total investable assets of the customer’s trust account. A signed contract between the Company and the customer is maintained for all customer trust accounts with payment terms identified. It is probable that the fees will be collectible as funds being managed are accessible by the asset manager. Past history of trust fee income recorded by the Company indicates that it is highly unlikely that a significant reversal could occur. There are no contingent incentive fees recorded by the Company that could be subject to a clawback in future periods.

Insurance Agency Commissions – Insurance agency commissions are received from insurance carriers for the agency’s share of commissions from customer premium payments. These commissions are recorded into income when checks are received from the insurance carriers, and there is no contingent portion associated with these commission checks. There may be a short time-lag in recording revenue when cash is received instead of recording the revenue when the policy is signed by the customer, but the time lag is insignificant and does not impact the revenue recognition process.

Insurance also receives incentive checks from the insurance carriers for achieving specified levels of production with particular carriers. These amounts are recorded into income when a check is received, and there are no contingent amounts associated with these payments that may be clawed back by the carrier in the future. Similar to the monthly commissions explained in the preceding paragraph, there may be a short time-lag in recording incentive revenue on a cash basis as opposed to estimating the amount of incentive revenue expected to be earned, this does not materially impact the recognition of Insurance revenue. If there were any amounts that would need to be refunded for one specific Insurance customer, management believes the reversal would not be significant.

Other potential situations surrounding the recognition of Insurance revenue include the estimating potential refunds due to the likely cancellation of a percentage of customers cancelling their policies and recording revenue at the time of policy renewals. Management concluded that since Insurance agency commissions represent only 2.3% of the Company’s total revenue, adjusting the current practice of recording insurance revenue for these situations would not have a material impact on the reporting of total revenue.

Retirement Plan Consulting Fees – Revenue is recognized based on the level of work performed for the client. Any payments that are received for work to be performed in the future are recorded in a deferred revenue account, and recorded into income when the fees are earned. Retirement plan consulting fees represent only 1.2% of the Company’s total revenue, and therefore management has concluded that any adjustment of revenue for one particular customer for a refund or any other reason would be insignificant and would not materially impact the Company’s total revenue.

Investment Commissions – Investment commissions are earned through the sales of non-deposit investment products to customers of the Company. The sales are conducted through a third-party broker-dealer. When the commissions are received and recorded into income on the Bank’s income statement, there is no contingent portion that may need to be refunded back to Cetera. Investment commissions represent only 1.0% of the Company’s total revenue, and therefore management has concluded that any adjustment of revenue for a particular customer for a refund or any other reason would be insignificant and would not materially impact the Company’s total revenue.

Other – Income items included in “Other” are Bank owned life insurance income, security gains, net gains on the sale of loans and other operating income. Any amounts within the scope of ASC 606 are deemed immaterial.