1


                                                             EXHIBIT 99

                     INDEPENDENT AUDITORS' REPORT

Board of Directors and Shareholder
First Interstate of Iowa, Inc.

  We have audited the consolidated income statement and changes in
shareholders' equity and cash flows of First Interstate of Iowa, Inc.
and subsidiaries for the year ended December 31, 1991 (not presented
separately herein). These consolidated financial statements are the
responsibility of the Company's management. Our responsibility is to
express an opinion on these consolidated financial statements based on
our audit.

  We conducted our audit in accordance with generally accepted auditing
standards. Those standards require that we plan and perform the audit
to obtain reasonable assurance about whether the financial statements
are free of material misstatement. An audit includes examining, on a
test basis, evidence supporting the amounts and disclosures in the
financial statements. An audit also includes assessing the accounting
principles used and significant estimates made by management, as well
as evaluating the overall financial statement presentation. We believe
that our audit provides a reasonable basis for our opinion

  In our opinion, the consolidated financial statements referred to
above present fairly, in all material respects, the results of
operations, changes in shareholders' equity, and cash flows of First
Interstate of Iowa, Inc. and subsidiaries for the year ended December
31, 1991 in conformity with generally accepted accounting principles.

                                 KPMG PEAT MARWICK

Des Moines, Iowa
January 31, 1992