7 The Comptroller of the Currency has held that "agency services arrangements that do not involve the exercise of discretion or similar fiduciary responsibilities, such as escrow, safekeeping and custody, may be performed by a bank under the incidental powers of banking without trust powers." Comptroller's Handbook for National Trust Examiners, Precedent and Opinion ¶ 9.2600, June, 1986.  Although the OCC's determinations represent an analysis of the law of a specific state and are not binding upon the Department, we agree with its opinion on this issue.