Minimum for an organization to be considered a financial institution?

Would a health insurance company who derives less than 5% of its revenue from asset management services(or any combination of other listed financial institution activities) be considered a financial institution?

Additionally would a business that is a bank that functions primarily to manage tax advantaged health/benefits accounts with all investment advisory and brokerage (all mutual funds) being managed by a third-party financial institution qualify as “retail and commercial banking activities”?