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                                                                     EXHIBIT (8)



                                   June 2, 1994



FIRST OF AMERICA BANK CORPORATION
211 South Rose Street
Kalamazoo, Michigan  49007

ATTENTION:  RICHARD K. MCCORD

 RE:  FEDERAL INCOME TAX CONSEQUENCES OF PROPOSED ACQUISITION OF FIRST PARK
      RIDGE CORPORATION

Greetings:

 You have requested our opinion regarding the federal income tax consequences
of First of America Bank Corporation's ("First of America") proposed
acquisition of First Park Ridge Corporation ("Park Ridge") through the merger
(the "Merger") of Park Ridge into a wholly owned subsidiary of First of
America.  Upon consummation of the Merger, outstanding shares of common stock
of Park Ridge will be converted into and exchanged for shares of the common
stock of First of America as described in the Agreement and Plan of Merger,
dated as of April 15, 1994, among First of America, First of
America-Acquisition Company and Park Ridge.

 For purposes of our opinion, we have examined the Prospectus/Proxy Statement
comprising part of First of America's Registration Statement on Form S-4 under
the Securities Act of 1933, as amended, and such other records, documents and
instruments, and have considered such matters of law, as in our judgment were
necessary or appropriate.  In addition, we have assumed that the facts set
forth in the Prospectus/Proxy Statement are accurate.  Any change in those
facts or any change of law after the date hereof could adversely affect our
opinion.

 Subject to the foregoing, we hereby confirm that our opinion as set forth in
the Prospectus/Proxy Statement under the caption "The Merger-- Federal Income
Tax Consequences" states the material federal income tax consequences of the
Merger.

 We consent to the filing of this opinion as Exhibit 8 to the Registration
Statement and to the reference to this Firm under the caption "The
Merger--Federal Income Tax Consequences" in the Prospectus/Proxy Statement
contained in the Registration Statement.

 This opinion is rendered pursuant to Item 4 of Form S-4 and Item 601 of
Regulation S-K, and may be relied upon only by First of America and the
Securities and Exchange Commission and may not be used, quoted or referred to
and/or filed with any other person without our written permission.

                                   VERY TRULY YOURS,

                                   HOWARD & HOWARD



                                   /S/ DAVID E. RIGGS
                                   ------------------                
                                   DAVID E. RIGGS