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EXHIBIT 21--SUBSIDIARIES OF THE REGISTRANT
CAPITOL BANCORP LTD.
DECEMBER 31, 1998




PAGE 1 OF 2                                                      STATE OR OTHER
                                                                 JURISDICTION
NAME OF SUBSIDIARY                                               OF INCORPORATION
- ------------------                                               ----------------

Consolidated Subsidiaries:
- --------------------------

                                                              
Ann Arbor Commerce Bank                                          Michigan

Brighton Commerce Bank (59% owned)                               Michigan

Capitol National Bank                                            United States (national bank)

Detroit Commerce Bank (93% owned)                                Michigan

Grand Haven Bank                                                 Michigan

Kent Commerce Bank (51% owned)                                   Michigan

Macomb Community Bank (51% owned)                                Michigan

Muskegon Commerce Bank (51% owned)                               Michigan

Oakland Commerce Bank                                            Michigan

Paragon Bank & Trust                                             Michigan

Portage Commerce Bank                                            Michigan

Sun Community Bancorp Limited (51% owned)                        Arizona
   Bank of Tucson
         (100% owned by Sun Community Bancorp Limited)           Arizona
   Valley First Community Bank
         (51% owned by Sun Community Bancorp Limited)            Arizona
   Camelback Community Bank
         (51% owned by Sun Community Bancorp Limited)            Arizona
   Southern Arizona Community Bank
         (51% owned by Sun Community Bancorp Limited)            Arizona
   Mesa Bank
         (51% owned by Sun Community Bancorp Limited)            Arizona
   Sunrise Bank of Arizona
         (51% owned by Sun Community Bancorp Limited)            Arizona

Capitol Trust I                                                  Delaware

Unconsolidated Subsidiary:

Amera Mortgage Corporation, Inc.                                 Michigan
(49% owned equity method investee)

Inactive subsidiaries:

MOI, Inc.                                                        Michigan
(wholly-owned subsidiary of
 Oakland Commerce Bank)

Financial Center Corporation                                     Michigan

C.B. Services, Inc.                                              Michigan




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EXHIBIT 21--SUBSIDIARIES OF THE REGISTRANT - CONTINUED:
CAPITOL BANCORP LTD.
DECEMBER 31, 1998

PAGE 2 OF 2


The following summarizes regulatory agencies of the registrant and its
subsidiaries:

The Corporation's state-chartered banks located in Michigan are regulated by the
Financial Institutions Bureau of the Michigan Department of Commerce. Capitol
National Bank, as a national bank, is regulated by the Office of the Comptroller
of the Currency. Bank subsidiaries located in Arizona are state-chartered and
are regulated by the Arizona Corporation Division. Each of the banking
subsidiaries, as federally-insured depository institutions, are also regulated
by the Federal Deposit Insurance Corporation. As a bank holding company, Capitol
Bancorp Ltd. is regulated by the Federal Reserve Board, which also regulates its
nonbanking subsidiaries. Sun Community Bancorp Limited is also regulated by the
Federal Reserve Board. In addition to the bank regulatory agencies, the
registrant and its subsidiaries are subject to regulation by other state and
federal agencies.