KPMG

KPMG LLP	Telephone   614 249 2300
Suite 500	Fax               614 249 2348
191 West Nationwide Boulevard	Internet        www.us.kpmg.com
Columbus, OH 43215-2568

Exhibit 16.1

July 23, 2004

Securities and Exchange Commission

450 Fifth Street, N.W.

Washington, D.C. 20549

Commissioners:

We have read the statements made by Banc One HELOC Trust 1998-1 (the “Trust”) which we understand will be filed with the Commission pursuant to Item 4 of Form 8-K as part of the Trust’s Form 8-K report dated as of July 1, 2004. We agree with the statements concerning our Firm in such Form 8-K, however our services to the Trust have not included the audit of any financial statements of the Trust.

Very truly yours,

/s/ KPMG LLP

Columbus, Ohio