are required to be held pursuant to banking regulations, (ii) deposits placed with the central bank (or equivalent thereof) in the corporation’s home country, and (iii) investments in debt instruments issued by the home country. (C) Substantial activity requirement for cross border income The term qualified banking or financing income shall not include income derived from 1 or more transactions with customers located in a country other than the home country of the eligible controlled foreign corporation unless such corporation conducts substantial activity with respect to a banking, financing, or similar business in its home country. (D) Direct conduct of activities For purposes of subparagraph (A)(ii)(II), an activity shall be treated as conducted directly by an eligible controlled foreign corporation in its home country if the activity is performed by employees of a related person and— (i) the related person is a resident subject to tax under the laws of the home country of the corporation to which subparagraph (A)(ii)(II) is being applied, (ii) the activity is performed in such home country, and (iii) the related person is compensated on an arm's-length basis for the performance of the activity by its employees and such compensation is treated as earned by such person in such home country for purposes of the home country's tax laws. (4) Lending, finance, or financial services business For purposes of this subsection, except as provided in regulations, the term lending, finance, or financial services business means the business of— (A) making loans, (B) purchasing, selling, discounting, or negotiating on a regular basis accounts receivable, notes, or installment obligations, (C) engaging in leasing (including entering into leases and purchasing, servicing, and disposing of leases and leased assets), (D) issuing letters of credit or providing guarantees, (E) providing charge and credit card services, (F) performing trust services, including as a fiduciary, agent, or custodian, other than trust services provided