At common law, the various kinds of banking, whether of issuing notes, discounting paper, or receiving deposits, were the privileges of any one who chose to exercise the right. This would seem to be the necessary conclusion from the development of banking. Originally the relation between a bank and its depositor was not that of debtor and creditor. Some of the greatest of the old European banks received money strictly as a deposit, to return the same money to its owner. But early in the history of banking it came to be a received notion that the relation of debtor and creditor was initiated by a so-called but misnamed deposit. "Whether the bank issued to its depositor an evidence of debt in the form of a note or notes, the amount being made payable on demand, or whether the credit was given the customer in his pass book or on the bank book, the obligation was precisely the same, to wit: a debt payable on demand. It therefore seems reasonably certain that banking continued to be at common law a privilege open to all. So the authorities agree.1