Commercial Federal Retirement Savings Plan
13220 California Street
Omaha, Nebraska  68154


We have read the  Company's  explanation  of the  reason  for the filing of Form
12b-25,  Notification for Late Filing. We concur that since adequate information
has not been provided to us by the Trustee of the Commercial  Federal Retirement
Savings Plan, the audit of the financial  statements  cannot be completed by the
filing deadline.


/s/ Deloitte & Touche LLP

Omaha, Nebraska
July 1, 2002