EXHIBIT 21

                           SUBSIDIARIES OF REGISTRANT

The registrant owns 100% of the issued and outstanding capital stock of TruServ
Acceptance Company, TruServ Logistic Company and General Paint and Manufacturing
Co., all Illinois corporations, Servistar Paint Company and Advocate Services
Incorporated, both Pennsylvania Corporations, TrueValue.com, a Delaware
Corporation, and is the sole member of TruServ Specialty Company, LLC, a
Delaware limited liability company. The accounts of these subsidiaries have been
consolidated with the registrant's in December 31, 2003 and 2002.