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Exhibit 8.2
XXXX XXXXXXX
XXXXX & XXXXXXXXXX
A PARTNERSHIP INCLUDING PROFESSIONAL CORPORATIONS
0000 X Xxxxxx, X.X.
Xxxxxxxxxx, X.X. 00000-0000
202.663.8000
Facsimile 202.663.8007
September 17, 1997
Chevy Chase Bank, F.S.B.
0000 Xxxxxxxxxxx Xxxxxx
Xxxxx Xxxxx, Xxxxxxxx 00000
Credit Suisse First Xxxxxx
Xxxxxx Xxxxxxx Xxxxxx
Xxx Xxxx, Xxx Xxxx 00000
X.X. Xxxxxx Securities Inc.
00 Xxxx Xxxxxx
Xxx Xxxx, Xxx Xxxx 00000
Xxxxx Xxxxxx Inc.
000 Xxxxxxxxx Xxxxxx
Xxx Xxxx, Xxx Xxxx 00000
Re: Chevy Chase Auto Receivables Trust 1997-3
Auto Receivables Backed Certificates, Class A
Registration Statement on Form S-3
(Registration No. 333-21707)
----------------------------------------------
Dear Sirs:
We have acted as special federal tax counsel to Chevy Chase Bank, F.S.B.
in connection with the issuance of the Chevy Chase Auto Receivables Trust 1997-
3, Auto Receivables Backed Certificates, Class A (the "Certificates") under the
above-referenced Registration Statement on Form S-3, as amended by Amendment No.
1 thereto ("Amendment No. 1" and together with such Registration Statement, the
"Registration Statement") filed with the Securities and Exchange Commission
under the Securities Act of 1933, as amended (the "Act") on March 11, 1997. The
Certificates will be issued pursuant to a Pooling and Servicing Agreement (the
"Pooling Agreement"), a form of which has been filed as Exhibit 4.3 to the
Registration Statement, to be entered into between Chevy Chase Bank, F.S.B. (the
"Bank") and U.S. Bank National Association, doing business as First Bank
National Association, as trustee (the "Trustee").
The statements in the preliminary Prospectus Supplement filed with the
Securities and Exchange Commission pursuant to Rule 424(b)(5) on September 17,
1997 (the "Prospectus Supplement") constituting a part of the Registration
Statement under the heading "Certain Federal Income Tax Consequences", to the
extent they constitute matters of federal law or legal conclusions with respect
thereto, have been prepared or reviewed by us and, in our opinion, provide a
fair and accurate summary of such law or conclusions.
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We consent to the use of this opinion in the Registration Statement
and to the reference to our name in the Prospectus Supplement constituting a
part of such Registration Statement under the caption "Legal Matters."
Very truly yours,
/s/ Shaw, Pittman, Xxxxx & Xxxxxxxxxx
Shaw, Pittman, Xxxxx & Xxxxxxxxxx
