EXHIBIT 33.1

           REPORT ON ASSESSMENT OF COMPLIANCE WITH SERVICING CRITERIA
                     PURSUANT TO ITEM 1122 OF REGULATION AB
                          FIRST NATIONAL BANK OF OMAHA

                                                            Date: March 27, 2009

The undersigned, a duly authorized representative of First National Bank of
Omaha (the "Servicer"), hereby certifies as follows:

     (1) The Servicer is responsible for assessing its compliance with the
servicing criteria set forth in 17 C.F.R. Section 229.1122(d) ("Item 1122(d) of
Regulation AB"), except for servicing criteria specified in (1)(iii); (2)(iii)
and (vi); 3(iii) and (iv); and 4(x) of Item 1122(d) of Regulation AB, which the
Servicer has determined are inapplicable to the activities it performs with
respect to the credit card asset backed securities transactions issued by First
National Master Note Trust (the "Platform") being serviced (such applicable
criteria, after giving effect to the exceptions identified above, the
"Applicable Servicing Criteria"), as of and for the year ended December 31, 2008
relating to the servicing of the Platform;

     (2) The Servicer used the servicing criteria in Item 1122(d) of Regulation
AB to assess compliance with the Applicable Servicing Criteria;

     (3) The Servicer is in compliance with the Applicable Servicing Criteria
relating to the Platform as of and for the year ending December 31, 2008 in all
material respects; and

     (4) Deloitte & Touche LLP, an independent registered public accounting
firm, has issued an attestation report for the Platform on the Servicer's
assessment of compliance with the Applicable Servicing Criteria as of and for
the year ending December 31, 2008.


                                        FIRST NATIONAL BANK OF OMAHA, as
                                        Servicer


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

              [Signature page to Report on Assessment of Compliance
                        of First National Bank of Omaha]