4. The prudential standards for Tier 1 FHCs –- including capital, liquidity and risk management standards –- should be stricter and more conservative than those applicable to other financial firms to account for the greater risks that their potential failure would impose on the financial system.
(p.25)
Restrictions on Nonfinancial Activities. Tier 1 FHCs that do not control insured depository institutions should be subject to the full range of prudential regulations and supervisory guidance applicable to BHCs. In addition, the long-standing wall between banking and commerce –- which has served our economy well –- should be extended to apply to this new class of financial firm. Accordingly, each Tier 1 FHC also should be required to comply with the nonfinancial activity restrictions of the BHC Act, regardless of whether it controls an insured depository institution. We propose that a Tier 1 FHC that has not been previously subject to the BHC Act should be given five years to conform to the existing activity restrictions imposed on FHCs by the BHC Act.