21 Id.; also see FDIC Financial Institution Letters 80-98 (July 16, 1998) and 61-95 (Sept. 12, 1995).  Additional supporting statements can be gleaned from other published materials.  See, e.g., FDIC Financial Institution Letter 48-97, page 13 (May 7, 1997) (A bank need not possess trust powers to offer self-directed custodial accounts); OCC Interpretive Letter No. 394 (Aug. 24, 1987) (A national bank must obtain trust powers prior to acting as trustee under Starker Trust agreements (used to facilitate a time-delayed, tax-free exchange of real property under Section 1031 of the Internal Revenue Code) even though its duties may be non-discretionary, because the arrangements appear to establish express trusts, unlike arrangements such as escrow, safekeeping and custody, including custodial, self-directed IRAs and Keogh plans).