I would think that "bank or financial institution" would be further defined somewhere else in the requirements.
In case it is not, then there are a couple of ways you can define a "financial institution"
According to
BusinessDictionary, a financial institution is:
I don't think an electrum wallet would meet this criteria because your electrum wallet is not allowing any of your funds to be borrowed while you are not using/spending them.
A more likely definition of "financial institution" would likely be how it is defined in
18 U.S. Code § 20:
As used in this title, the term “financial institution” means—
(1) an insured depository institution (as defined in section 3(c)(2) of the Federal Deposit Insurance Act);
(2) a credit union with accounts insured by the National Credit Union Share Insurance Fund;
(3) a Federal home loan bank or a member, as defined in section 2 of the Federal Home Loan Bank Act (12 U.S.C. 1422), of the Federal home loan bank system;
(4) a System institution of the Farm Credit System, as defined in section 5.35(3) of the Farm Credit Act of 1971;
(5) a small business investment company, as defined in section 103 of the Small Business Investment Act of 1958 (15 U.S.C. 662);
(6) a depository institution holding company (as defined in section 3(w)(1) of the Federal Deposit Insurance Act;
(7) a Federal Reserve bank or a member bank of the Federal Reserve System;
(8) an organization operating under section 25 or section 25(a) [1] of the Federal Reserve Act;
(9) a branch or agency of a foreign bank (as such terms are defined in paragraphs (1) and (3) of section 1(b) of the International Banking Act of 1978); or
(10) a mortgage lending business (as defined in section 27 of this title) or any person or entity that makes in whole or in part a federally related mortgage loan as defined in section 3 of the Real Estate Settlement Procedures Act of 1974.
I have not looked into the definitions as listed in the above statutes, however I would doubt that an electrum wallet would be described above.
It is possible that an exchange account at an exchange like bitfinex might meet the definition of a "financial institution" as bitfinex does serve as a platform between lenders and borrowers for margin lending.