Nope. You're a bank in this case. A bank is someone who accepts demand deposits, that is, money they give to you which you give them back when they want it.
What you are, is someone who is issuing redeemable notes. Issuing notes will not, _per se_, make you a bank. Or alternatively you are a trustee. If I gave money to my escrow agent, to be paid to me when I want it, she would not be a bank. If the value transferred is liquid, and the payment is made upon demand, then, in fact, you are a bank, regardless of what else you might call yourself. This is the case in the USA. Canada certainly varies, as does the rest of the world. [...] but the key element in all of these matters is jurisdiction. Who regulates all of this? The answer of course is no one. This is a rather hasty conclusion. The real answer is that a country will attempt to regulate this activity if it feels like it can argue jurisdiction and win. The easiest barrier to erect is to get some country to claim jurisdiction; the others will then generally stay away with their courts. If there is no stated location, then a country can simply claim jurisdiction if some of the facts of the situation give it an arguable jurisdiction. If, for example, the computers for a cypherspace bank are known to be in the USA and the bank claims to be outside USA jurisdiction, guess who wins. This would mean that the bank, would be everywhere simultaneously, without being anywhere at all. One can imagine all sorts of things, but architectures that can be built and economically deployed are much more important than vague characteristics. The problem of making a jurisdiction-less bank is a mighty difficult one, and it behooves those who wish to discuss it to ground their comments in economic and political realpolitik. Eric