Anchorage will have conditional authorization to operate as a trust institution nationally. The charter is the first of its kind, part of an idea of a "fintech charter" stretching back to the Obama years, but which has been accelerated under the leadership of Acting Comptroller Brian Brooks, formerly of Coinbase's legal team. However, the actual agreement between Anchorage and the OCC specifies a point that has been central to the debate around the fintech charter; namely, that the new species of banks will not hold deposits.