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                                                                     Exhibit 5.1

                            National City Corporation
                             1900 East Ninth Street
                            Cleveland, OH 44114-3484

                                 April 13, 2001


Ladies and Gentlemen:

         The law department acts as counsel to National Processing, Inc. (the
"Company") and in connection with the filing on Form S-3 Registration Statement
registering shares of Common Stock, without par value, (the "Common Stock") in
connection with the National City Savings and Investment Plan, the National City
Savings and Investment Plan No. 2 and the Savings and Investment Plan No. 3 (all
these plans referred to collectively as the "Plans") and with participations
therein (the "Registration Statement").

         We have examined such documents, records and matters of law as we have
deemed necessary for purposes of this opinion. In our examination, we have
assumed the validity of all signatures, the legal capacity of all natural
persons, the authenticity of all documents submitted to us as originals, the
conformity to original documents of all documents submitted to us as certified
or photostatic copies, and the authenticity of the originals of such copies.

         Based on the foregoing we are of the opinion that:

         1.       The shares of Common Stock outstanding on the date hereof
                  which may be purchased by the Plans and delivered to
                  participants pursuant to the Plans will be, when purchased and
                  delivered in accordance with the Plans, duly authorized,
                  validly issued, fully paid and nonassessable:

         2.       The shares of Common Stock which may be issued or transferred
                  pursuant to the Plans will be, when issued or transferred in
                  accordance with the Plans, duly authorized, validly issued,
                  fully paid and nonassessable so long as:

                  (a)      the consideration received or to be received by the
                           Corporation is at least equal to the par value of
                           such shares; and

                  (b)      the issuance of any newly issued shares, and the
                           transfer of any treasury shares, are duly authorized
                           prior to any such issuance or transfer.



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         3.       The participations to be extended to participants in such
                  Plans will be validly issued when extended in accordance with
                  such Plans.

         We hereby consent to the filing of this opinion as Exhibit 5.1 to the
Registration Statement and to the reference to us, as counsel for the Company
under the caption "Legal Opinions" in the prospectus comprising a part of such
Registration Statement.

                                         Very truly yours,

                                         /s/ Carlton E. Langer

                                         Carlton E. Langer
                                         Vice President and Assistant Secretary,
                                         National City Corporation