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Why Banks Should Not Be In Real Estate Business Real Estate Brokerage/Management Are Commercial Not Banking Activities The brokering of the sale or purchase of a home is no different from the brokering of the sale or purchase of an automobile, boat or collectable fine art. All four are highly priced tangible assets where a high percentage of their transactions involve financing. Even the Federal Reserve's own staff stated, [F] inancial assets are generally thought to include money, loans, securities, and other intangible, contractual rights to a payment stream. Real estate, on the other hand, is a tangible, physical asset that is not used as a currency for payment transactions." There Have Been No Significant Changes In The Marketplace Or Technology The Gramm-Leach-Bliley Act (GLB Act) requires that the Federal Reserve take into account changes in the marketplace and changes in the technology for delivering financial services. There have been no significant changes in the marketplace or in the technology for delivering financial services since the passage of the GLB Act. Federally Chartered Advantages of Financial Holding Companies: Unleveling the Playing Field Permitted to enter the real estate brokerage/management industry, financial holding companies, FHCs, possess advantages not held by their real estate brokerage competitors. The real estate brokerage industry is already characterized by fierce competition, market efficiencies, and ease of entry so that there is nothing gained for consumers by permitting FHCs entrance. On the contrary, due to their Federally-chartered advantages, ownership of real estate brokerage companies would stifle competition, limit consumer choices and predictably raise consumer costs. Further, exploiting these advantages in the commercial arena would place an unnecessary burden on U.S. taxpayers as well as create unintended consequences on the safety and soundness of the nation's banking system. Federal subsidies received by financial holding companies provide a downstream advantage to their subsidiaries. Federally-Chartered Advantages: Federal Deposit Insurance. Many Banks are considered "Too Big To Fail". Access to Federal Reserve Discount Window. Access to the Nation's Payment System. Allowed Greater Leverage than Non-Bank Companies. Access to Federal Home Loan Banks to Increase Liquidity. High Entry Barriers in Banking.