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                                                                      EXHIBIT 21

                                     KEYCORP
               SUBSIDIARIES OF THE REGISTRANT AT DECEMBER 31, 2004



                                 JURISDICTION
                               OF INCORPORATION
        SUBSIDIARIES(a)         OR ORGANIZATION    PARENT COMPANY
- -----------------------------  ----------------  -------------------
                                           
KeyBank National Association    United States        KeyCorp


(a) Subsidiaries of KeyCorp other than KeyBank National Association are not
    listed above since, in the aggregate, they would not constitute a
    significant subsidiary. KeyBank National Association is 100% owned by
    KeyCorp.