April 12, 2005


Mail Stop 4-8

Christopher Carey
Chief Financial Officer
City National Corporation
400 North Roxbury Drive
Beverly Hills, California 90210

Re:	Form 10-K
	Filed March 15, 2005
	File No. 001-10521

Dear Mr. Carey:

      We have reviewed your filing and have the following
comments.
We have limited our review to only the issues raised in our
comments.
Where indicated, we think you should revise your document in
response
to these comments in future filings.  If you disagree, we will
consider your explanation as to why our comment is inapplicable or
a
revision is unnecessary.  Please be as detailed as necessary in
your
explanation.  In some of our comments, we may ask you to provide
us
with supplemental information so we may better understand your
disclosure.  After reviewing this information, we may or may not
raise additional comments.

	Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or any other aspect
of
our review.  Feel free to call us at the telephone numbers listed
at
the end of this letter.

Accounting for Derivatives and Hedging Activity - page A-6
1. Please revise your disclosures for your fair value and cash
flow
hedges as follows:
* Describe how and when you test your hedges to determine that
they
meet the criteria for initial and subsequent period hedge
accounting;
* Disclose where you report realized and unrealized gains and
losses
on hedges and hedged items in your statement of income; and
* Specifically disclose the hedged item for each of your hedges.

Supplementally provide us with your proposed disclosures.

Provision for Credit Losses - page A-13
2. We note that you have not recorded a provision for credit loss
since the second quarter of 2003.  Please revise your discussion
of
the results of operations in MD&A to specifically discuss the
changes
in asset quality, to explain how those changes have affected your
allowance for loan losses and the provision for credit losses and
to
discuss the related trends on income.


* * * * *


      Please respond to these comments within 10 business days or
tell us when you will provide us with a response.  Please furnish
a
cover letter that keys your responses to our comments, indicates
your
intent to include the requested revisions in future filings and
provides any requested supplemental information.  Please
understand
that we may have additional comments after reviewing your
responses
to our comments.

	We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing reviewed by the staff to
be
certain that they have provided all information investors require
for
an informed decision.  Since the company and its management are in
possession of all facts relating to a company`s disclosure, they
are
responsible for the accuracy and adequacy of the disclosures they
have made.

	In connection with responding to our comments, please
provide,
in writing, a statement from the company acknowledging that:

* the company is responsible for the adequacy and accuracy of the
disclosure in the filing;

* staff comments or changes to disclosure in response to staff
comments do not foreclose the Commission from taking any action
with
respect to the filing; and

* the company may not assert staff comments as a defense in any
proceeding initiated by the Commission or any person under the
federal securities laws of the United States.

      In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in our review of your filing or in
response to our comments on your filing.

      You may contact Michael Volley, Staff Accountant, at (202)
824-
5568 or me at (202) 942-1782 if you have questions.

Sincerely,



Paul Cline
Senior Accountant

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Christopher Carey
City National Corporation
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