There is much current discussion about letting bank holding companies (BHCs) engage in certain financial lines of business outside commercial banking.1 Large BHCs have argued vigorously for lowering barriers to entry into investment banking, full service securities brokerage, insurance, and real estate investment and development. These BHCs point out that nonbank financial firms such as securities firms and insurance companies have been permitted into traditional banking activities. They argue that lowering the entry barriers into nonbank activities would not only be equitable—by leveling the playing field—but would also bring some needed competition into nonbank areas.2 This viewpoint has gained considerable support from bank regulatory agencies, the Administration, and influential members of the Senate Banking Committee. As a result, several bills have been introduced in Congress that would lower the legal barriers for BHC entry into one or more of these activities.