EXHIBIT 35.1

                          SERVICER COMPLIANCE STATEMENT
                     PURSUANT TO ITEM 1123 OF REGULATION AB

                          FIRST NATIONAL BANK OF OMAHA

                                                            Date: March 27, 2009

     The undersigned, a duly authorized officer of First National Bank of Omaha
(the "Servicer"), pursuant to Item 1123 of Regulation AB, Section 3.05(a) of the
Second Amended and Restated Pooling and Servicing Agreement dated as of October
24, 2002, among First National Funding LLC, as Transferor, First National Bank
of Omaha, as Servicer, and The Bank of New York Trust Company, N.A., as
successor trustee to The Bank of New York, as Trustee, as amended (the "Pooling
and Servicing Agreement")(1) and Section 3.05(a) of the Transfer and Servicing
Agreement, dated as of October 24, 2002, among First National Funding LLC, as
Transferor, First National Bank of Omaha, as Servicer, and First National Master
Note Trust, as Issuer, as amended (the "Transfer and Servicing Agreement"), does
hereby certify that:

     1. A review of the activities of the Servicer from January 1, 2008 through
December 31, 2008 (the "Reporting Period") and of its performance under the
Pooling and Servicing Agreement and the Transfer and Servicing Agreement has
been made under my supervision; and

     2. To the best of my knowledge, based on my review, the Servicer has
fulfilled all of its obligations under the Pooling and Servicing Agreement and
the Transfer and Servicing Agreement, in all material respects throughout the
Reporting Period.

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(1)  On December 18, 2008 (the "Certificate Trust Termination Date"), the
     Transferor exercised its option to terminate First Bankcard Master Credit
     Card Trust and the Pooling and Servicing Agreement. On and after the
     Certificate Trust Termination Date, the Receivables are serviced by the
     Servicer as provided in the Transfer and Servicing Agreement.



     IN WITNESS WHEREOF, I have signed this Servicer Compliance Statement the
day and year first written above.

                                        FIRST NATIONAL BANK OF OMAHA, as
                                        Servicer


                                        By /s/ Timothy D. Hart
                                           -------------------------------------
                                           Timothy D. Hart
                                           Senior Vice President