It is also obviously not a fractional reserve bank. The notion of voluntary FRB can be shown to be logically impossible. See for example here:
https://forum.freecapitalists.org/t/kaz-on-free-banking/16861/10
Also, the argument over whether it is fraud isn’t an ethical argument as some have asserted here. Fraud is a means to an end (although it could be also an end). One can conclude that FRB is fraud without making value judgments. Such an argument must be made on the baiss of praxeolgoy. It just so happens that practically everybody considers fraud as an immoral act.