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”?

Please refer to this thread for the response to a similar question.

Investments managed under discretionary mandates are required to be covered by targets while investments administered (on behalf of third parties) under advisory or execution-only mandates are optional. If an FI can make investment decisions or have been or is involved in designing the investment strategy (i.e. have had or has some influence over fund/security selection and/or can vote for the securities in its portfolio), these assets shall be included in the target boundary.