EXHIBIT 21

                                    KEYCORP
              SUBSIDIARIES OF THE REGISTRANT AT FEBRUARY 28, 2002



                                                  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.

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