<PAGE>
                                                                    EXHIBIT 99.2
                                                                    ------------

                        Report of Independent Accountants


To  the  Board  of  Directors  of
Bank  of  America,  N.A.  (USA)

We  have examined management's assertion, included in the accompanying Report of
Management  on  Compliance  with  Pooling  and Servicing Agreement, that Bank of
America,  N.A.  (USA),  formerly  Bank  of  America  National  Association, (the
"Company")  maintained an effective system of internal control over servicing of
accounts  and  over safeguarding of assets against unauthorized acquisition, use
or disposition as of December 31, 2000, in compliance with BA Master Credit Card
Trust  Pooling  and Servicing Agreement dated July 19, 1996, as amended December
18,  1998 and including the Series 1996-A, the Series 1996-B, the Series 1997-A,
the  Series 1997-B, the Series 1997-C, the Series 1998-A, the Series 1998-B, the
Series  1998-C,  the  Series  1999-A,  the  Series  1999-B and the Series 1999-C
Supplements  (collectively, the "Agreement"), between the Company, as Transferor
and  Servicer,  and U.S. Bank National Association, formerly First Bank National
Association, as Trustee.  We have also examined management's assertion, included
in  the  accompanying  Report  of  Management  on  Compliance  with  Pooling and
Servicing  Agreement, about the Company's compliance with sections 3.01(b-d, f),
3.02, 3.04(b), 3.05, 3.08, 3.09, 4.02, 4.03, 4.05, 4.06, 4.07, 4.08, 4.09, 4.10,
4.11, 4.12, 4.13, 4.14, 4.15, 4.16, 4.17, 4.18 and 8.08 - and as to section 4.19
with  respect  to  the Series 1996-B and the Series 1997-B Supplements and as to
section  13.05 where applicable in the previously delineated sections and except
for  references  from  such sections to a section (and references therefrom) not
specifically delineated herein - of the Agreement for the period January 1, 2000
to  December  31,  2000  for  the  Series  1996-A, the Series 1996-B, the Series
1997-A,  the  Series  1997-B,  the  Series 1997-C, the Series 1998-A, the Series
1998-B,  the  Series 1998-C, the Series 1999-A, the Series 1999-B and the Series
1999-C  (collectively,  the  "Series").  The Company's management is responsible
for  the  maintaining  an effective system of internal control over servicing of
accounts  and  over safeguarding of assets against unauthorized acquisition, use
or  disposition  in  compliance  with  the  Agreement  (hereafter referred to as
"servicing"),  and  for  compliance  with  the  aforementioned  sections  of the
Agreement.  Our  responsibility  is  to  express  an  opinion  on  management's
assertions.

Our  examinations were conducted in accordance with standards established by the
American  Institute  of  Certified Public Accountants and, accordingly, included
obtaining  an understanding of the Company's internal control over servicing and
evaluating  the  design  and  operating  effectiveness of internal control as of
December  31,  2000.  Our examinations also included examining, on a test basis,
evidence  about the Company's compliance with the aforementioned sections of the
Agreement for the period January 1, 2000 to December 31, 2000 for the Series and
performing  such  other  procedures  as  we  considered  necessary  in  the
circumstances.  We  believe that our examinations provide a reasonable basis for
our  opinion.

Because  of  inherent  limitations in any internal control, misstatements due to
error  or  fraud  may  occur  and  not  be  detected.  Also,  projections of any
evaluation  of  the  internal  control  over  compliance  with  the  specified
requirements of the Agreement to future periods are subject to the risk that the
internal control may become inadequate because of changes in conditions, or that
the  degree  of  compliance  with  the  policies and procedures may deteriorate.

In our opinion, management's assertions that the Company maintained an effective
system  of  internal  control over servicing as of December 31, 2000, based upon
the  criteria  for  effective  internal  control described in Internal Control -
Integrated  Framework issued by the Committee of Sponsoring Organizations of the
Treadway  Commission,  and  that  the  Company  complied with the aforementioned
sections  of  the Agreement for the period January 1, 2000 to December 31, 2000,
are  fairly  stated,  in  all  material  respects  for  the  Series.




March  22,  2001

<PAGE>

<PAGE>

           Report of Management on Credit Card Trust Internal Controls
                 and Pooling and Servicing Agreement Compliance


Internal  Controls

The management of Bank of America, N.A. (USA), formerly Bank of America National
Association,  (the "Company") is responsible for establishing and maintaining an
effective  system  of  internal  control  over  servicing  of  accounts and over
safeguarding  of  assets against unauthorized acquisition, use or disposition in
compliance  with  BA  Master  Credit  Card Trust Pooling and Servicing Agreement
dated  July 19, 1996, as amended December 18, 1998, including the Series 1996-A,
the  Series 1996-B, the Series 1997-A, the Series 1997-B, the Series 1997-C, the
Series  1998-A,  the  Series  1998-B,  the Series 1998-C, the Series 1999-A, the
Series 1999-B and the Series 1999-C Supplements (collectively, the "Agreement"),
between  the  Company,  as  Transferor  and  Servicer,  and  U.S.  Bank National
Association,  formerly  First  Bank National Association, as Trustee. The system
contains  monitoring  mechanisms,  with  actions  taken  to  correct  identified
deficiencies.  Even  an  effective  internal  control system, no matter how well
designed, has inherent limitations, including the possibility of human error and
the  circumvention  or  overriding  of controls, and therefore, can provide only
reasonable  assurance  with  respect  to  the  servicing  of  accounts  and  the
safeguarding  of  assets against unauthorized acquisition, use or disposition in
compliance  with  the Agreement.  Further, because of changes in conditions, the
effectiveness  of  an  internal  control  system  may  vary  over  time.

Management  has  assessed its internal control system over servicing of accounts
and  over safeguarding of assets in compliance with the Agreement as of December
31,  2000.  This assessment was based on criteria for effective internal control
described  in Internal Control - Integrated Framework issued by the Committee of
Sponsoring  Organizations  of  the Treadway Commission, insofar as such criteria
related  to  servicing of accounts and safeguarding of assets in compliance with
the  Agreement.  Based  on this assessment, management believes that the Company
maintained  an  effective  system of internal control over servicing of accounts
and  over  safeguarding  of  assets  against  unauthorized  acquisition,  use or
disposition  in  compliance  with the Agreement as of December 31, 2000 and that
for  the  period     January  1,  2000  to  December 31, 2000 the Company was in
compliance  with  the  Agreement  in  all  material  respects.

March  22,  2001

/s/Terry  L.  Schappert     /s/Cynthia  A.  Brimacombe
-----------------------     --------------------------
Terry  L.  Schappert     Cynthia  A.  Brimacombe
Senior  Vice  President     Vice  President

/s/Victoria  Jahanbani
----------------------
Victoria  Jahanbani
Vice  President