Exhibit 8.1

              [Letterhead of Orrick, Herrington & Sutcliffe LLP]


                                April 24, 2001


MBNA America Bank,
 National Association
1100 North King Street
Wilmington, Delaware 19884

Re:  MBNA America Bank, National Association
     MBNA Master Credit Card Trust II
     MBNA Credit Card Master Note Trust
     Registration Statement on Form S-3
     ----------------------------------------------------------------------

Ladies and Gentlemen:

     We have acted as counsel for MBNA America Bank, National Association, a
national banking association (the "Bank"), in connection with the preparation of
the Registration Statement on Form S-3 (the "Registration Statement"), which has
been filed on April 24, 2001 with the Securities and Exchange Commission under
the Securities Act of 1933, as amended (the "Act"), for the registration under
the Act of series (each, a "Series") of notes (collectively, the "Notes"), each
such Series of Notes representing obligations of the MBNA Credit Card Master
Note Trust (the "Trust") and for the registration under the Act of the Series
2001-[.] certificate (the "Collateral Certificate") representing an obligation
of MBNA Master Credit Card Trust II (the "Master Trust"). Each Series of Notes
will be issued pursuant to an Indenture (the "Master Indenture"), as
supplemented by an Indenture Supplement relating to such Series (each, an
"Indenture Supplement" and, in each such case, together with the Master
Indenture, the "Indenture"), in each case between the Trust and The Bank of New
York, as Indenture Trustee. The Collateral Certificate will be issued pursuant
to the Pooling and Servicing Agreement between the Bank, as Seller and Servicer,
and The Bank of New York, as trustee of the Master Trust (the "Trustee"), dated
as of August 4, 1994, and a supplement thereto between the Bank and the Trustee.

     We hereby confirm that the statements set forth in the prospectus (the
"Prospectus") relating to the Notes forming a part of the Registration Statement
under the headings "Prospectus Summary

MBNA America Bank,
 National Association
April 24, 2001
Page 2

- - Tax Status" and "Federal Income Tax Consequences," which statements have been
prepared by us, to the extent that they constitute matters of law or legal
conclusions with respect thereto, are correct in all material respects, and we
hereby adopt and confirm the opinions set forth therein.

     The above-referenced description of federal income tax consequences and
opinions does not relate to any transaction which requires modification of such
description and opinions in the context of such transaction.

     We hereby consent to the filing of this opinion as an exhibit to the
Registration Statement. We also consent to the reference to Orrick, Herrington &
Sutcliffe LLP under the captions "Legal Matters," "Prospectus Summary - Tax
Status" and "Federal Income Tax Consequences," in the Prospectus. In giving such
consent, we do not admit that we are "experts," within the meaning of the term
used in the Act or the rules and regulations of the Securities and Exchange
Commission issued thereunder, with respect to any part of the Registration
Statement, including this opinion as an exhibit or otherwise.

                                        Very truly yours,

                                        /s/ Orrick, Herrington & Sutcliffe LLP

                                        ORRICK, HERRINGTON & SUTCLIFFE LLP