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                                                                     EXHIBIT 99B

      Report on Applying Agreed-Upon Procedures of Independent Accountants

National City Corporation
Cleveland, Ohio

The Bank of New York
New York, New York

We have performed the procedures enumerated below, which were agreed to by the
managements of National City Corporation (National City) and The Bank of New
York, solely to assist you in evaluating the servicing of certain credit card
receivables during the period January 1, 1999, through December 31, 1999, for
compliance with the terms and conditions set forth in the Pooling and Servicing
Agreement (the "Agreement") dated June 1, 1995, as supplemented by the Series
1995-1 Supplement (the "Supplement"), for the First of America Credit Card
Master Trust (the "Trust") among National City Bank, as Seller and Servicer,
and The Bank of New York, as Trustee. The credit card receivables are
identified in Schedule 1 of the Agreement.

We performed the following agreed-upon procedures (unless otherwise indicated,
the capitalized terms have the meanings set forth in the Agreement):

1.   We obtained the monthly certificateholder's statement for the collection
     period January 1, 1999, to December 31, 1999, from the management of
     National City from the monthly certificateholder's statement, we agreed
     amounts per the statement to system-generated reports and/or documents
     received from The Bank of New York or The Union Bank of Switzerland that
     were the source of such amounts. For the percentages presented in the
     monthly certificateholder's statement, we recalculated the percentage based
     upon the formula provided in the Agreement and the amounts obtained from
     the source document.

     In one instance, the Class B deficit controlled amortization amount was
     improperly reported. No other exceptions were noted.

2.   We inquired of National City management as to whether the collection and
     charge off of payments are in accordance with National City's customary and
     usual servicing procedures.

     National City management indicated in the affirmative.


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3.   For expenses incurred in connection with the Trust and the related
     servicing activities, we inquired of National City management that
     National City paid all expenses in 1999 out of its own funds,
     without reimbursement from the Trust.

     National City management indicated that National City paid such expenses
     without reimbursement from the Trust.

4.   We obtained the monthly certificateholder's statements for the year from
     National City management. We compared the monthly servicing fee per the
     statements to source documentation and determined the monthly servicing
     fee was based on the product of (a) the weighted average servicing fee
     rates and (b) the amount of principal receivable on the last day of the
     prior Monthly Period.

     No exceptions were noted.

5.   We inquired of National City management that not later than the third
     business day preceding each distribution date during 1999, National City
     delivered to the Trustee, Paying Agent, each Rating Agency and each Series
     Enhancer, a certificate in substantially the form set forth in the
     Supplement.

     National City indicated that such certificates were delivered timely.

6.   For adjustments downward of any Principal Receivable in 1999, we inquired
     of National City management that the amount of Principal Receivables
     are reduced by the amount of the required adjustment in calculating
     the Seller Amount, the Seller Interest, the Floating Allocation
     Percentage and the Principal Allocation Percentage. Additionally, we
     inquired of National City management that adjustments are made on or
     prior to the end of the Monthly Period in which such adjustment
     obligation arises.

     National City management indicated that no adjustment downward of
     Principal Receivable occurred for the year ended December 31, 1999.

7.   We obtained the deposit account statement for the Collection Account for
     each month during 1999 to determine the monthly deposit was made in
     immediately available funds no later than 12:00 noon, New York City, New
     York time, on the related Transfer Date for each month. Additionally, to
     determine the aggregate amount of required Collections was deposited, we
     agreed the amount deposited per the deposit account statement to
     system-generated reports identifying the required amount for the monthly
     deposits for each month during 1999. We also identified that each account
     bears a designation clearly indicating that the funds deposited therein
     are held for the benefit of the Certificateholders.

     No exceptions were noted.
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8.   We recalculated the monthly allocation of the Collections of Finance
     Charge Receivables, Defaulted Amount and Collections of Principal
     Receivable for each month during 1999, to determine amounts were
     calculated in accordance with Section 4.03(b) of the Agreement. We
     recalculated such allocations based upon system-generated reports which
     represent the source of such amounts.

     No exceptions were noted.

9.   We inquired of National City management of the processes of allocating
     shared principal collections, pro rata, to each investor, in proportion to
     the principal shortfall and allocating the Excess Finance Charge
     Collections, pro rata, in proportion to the Finance Charge Shortfalls, if
     any, to determine compliance with Sections 4.04 and 4.05, respectively, of
     the Agreement.

     National City management indicated this process is not applicable to
     National City as of and for the year ended December 31, 1999.

10.  We inquired of National City management that the Servicer established an
     Eligible Deposit Account as a prefunding account to comply with
     Section 4.06 of the Agreement.

     National City management indicated the Servicer has not established an
     Eligible Deposit Account as of and for the year ended December 31, 1999.

11.  We recalculated the Servicer's calculation of interchange and recoveries
     for one month during the period, October, 1999, by using source
     documentation to determine amounts were calculated in accordance with the
     Section 4.07 of the Agreement.

     No exceptions were noted.

12.  We inquired of National City management that the methodology utilized to
     identify securitized receivables on their system provided, in the computer
     files, a clear and unambiguous indication that the securitized receivable
     accounts have been conveyed for the benefit of investors.

     National City indicated in the affirmative.

13.  We inquired of National City management if there had been any amendments
     made to the Agreement during the year that would impact the agreed-upon
     procedures to be performed.
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     National City management indicated there were no amendments made to the
     Agreement during the year ended December 31, 1999, that would impact
     the agreed-upon procedures as of and for the period then ended.

Our engagement to apply agreed-upon procedures was performed in accordance with
attestation standards established by the American Institute of Certified Public
Accountants. The sufficiency of the procedures is solely the responsibility of
the specified users of the report. Consequently, we make no representation
regarding the sufficiency of the procedures either for the purpose for which
this report is being prepared or for any other purpose.

We were not engaged to, and did not, perform an examination, the objective of
which would be the expression of an opinion on the servicing of certain credit
card receivables. Accordingly, we do not express such an opinion. Had we
performed additional procedures, other matters might have come to our attention
that would have been reported to you.

Our report is intended solely for the use of National City and The Bank of New
York and should not be used by those who have not agreed to the procedures and
taken responsibility for the sufficiency of the procedures for their purposes.



March 15, 2000

                                                          /s/ Ernst & Young LLP