Any services provided by the financial institution or its employees must be financial in nature as you state in order to get credit for community development services. This doesn't apply to the provision of "community services" by non-bank organizations. So you could provide financing to a daycare center, or a medical services provider, etc that serves primarily low- or moderate-income people and get credit for that as community development lending or investing. But your point about the limitation for services rendered by the bank or its employees is correct.
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