The regulation has definitions of what is and what is not a financial institution covered by the rules. The regulations state " An investment advisory company and a credit counseling service are each financial institutions because providing financial and investment advisory services are financial activities referenced in section 4(k)(4)(C) of the Bank Holding Company Act."
I'm not sure if this accurately describes your situation as you said the affiliates offer mutual funds and insurance and later that they act as brokers.
I would certainly contact legal counsel if you are not sure as the mandatory compliance date is drawing near.
Dolly Nugent
Vice President
Compliance & CRA Officer
Citizens Business Bank