[LETTERHEAD]
                                                                       Exhibit 8


                                             September 23, 1998



Fleet Financial Group, Inc.
One Federal Street
Boston, Massachusetts  02110

Fleet Capital Trust V,
Fleet Capital Trust VI,
Fleet Capital Trust VII,
Fleet Capital Trust VIII,
Fleet Capital Trust IX, and
Fleet Capital Trust X
c/o Fleet Financial Group, Inc.
One Federal Street
Boston, Massachusetts  02110

Re:      Registration Statement on Form S-3
         Registration No. 333-62905

Ladies and Gentlemen:

         We have acted as counsel to Fleet Financial Group, Inc., a Rhode Island
corporation (the "Company"), and each of Fleet Capital Trust V, Fleet Capital
Trust VI, Fleet Capital Trust VII, Fleet Capital Trust VIII, Fleet Capital Trust
IX and Fleet Capital Trust X, statutory business trusts formed under the laws of
the State of Delaware (the "Trusts"), in connection with the above-captioned
registration statement on Form S-3 (the "Registration Statement") filed with the
Securities and Exchange Commission (the "Commission") for the purpose of
registering (i) Preferred Securities representing undivided beneficial interests
in the assets of the Trust and (ii) Junior Subordinated Debentures issued by the
Company to the Trust, in connection with the sale of the Preferred Securities.
All capitalized terms used herein and not otherwise defined shall have the
meanings set forth in the form of Prospectus Supplement for an offering of
Preferred Securities filed as an exhibit to the Registration Statement (the
"Form of Prospectus Supplement").

         We hereby confirm that, although the discussion set forth under the
heading "UNITED STATES FEDERAL INCOME TAXATION" in the form of Prospectus





Fleet Financial Group, Inc.
September 23, 1998
Page 2


Supplement does not purport to discuss all possible United States
federal income tax consequences of the purchase, ownership and disposition of
Preferred Securities, in our opinion, such discussion constitutes, in all
material respects, a fair and accurate summary of the United States federal
income tax consequences of the purchase, ownership and disposition of Preferred
Securities, based upon current law. It is possible that contrary positions may
be taken by the Internal Revenue Service and that a court may agree with such
contrary positions.

         This opinion is furnished to you solely for your benefit in connection
with the filing of the Registration Statement and, except as set forth below, is
not to be used, circulated, quoted or otherwise referred to for any other
purpose or relied upon by any other person for any purpose without our prior
written consent. We hereby consent to the use of our name under the heading
"Legal Matters" in the Form of Prospectus Supplement and the filing of this
opinion with the Commission as Exhibit 8 to the Registration Statement. In
giving this consent, we do not thereby admit that we are within the category of
persons whose consent is required under Section 7 of the Securities Act of 1933,
as amended, or the rules and regulations of the Commission promulgated
thereunder. This opinion is expressed as of the date hereof unless otherwise
expressly stated and applies only to the disclosure under the heading 
"UNITED STATES FEDERAL INCOME TAXATION" set forth in the Form of Prospectus
Supplement filed as of the date hereof. We disclaim any undertaking to advise
you of any subsequent changes of the facts stated or assumed herein or any
subsequent changes in applicable law.


                                              Very truly yours,

                                              /s/ EDWARDS & ANGELL, LLP
                                              -------------------------
                                              EDWARDS & ANGELL, LLP


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