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Exhibit 8.3
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
December 9, 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
Salomon Brothers Inc
000 Xxxxxxxxx Xxxxxx
Xxx Xxxx, Xxx Xxxx 00000
Re: Chevy Chase Auto Receivables Trust 1997-4
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.
(the "Bank") in connection with the issuance of the Chevy Chase Auto Receivables
Trust 1997-4, 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") declared effective by the Securities
and Exchange Commission under the Securities Act of 1933, as amended (the
"Act"), at 4:30 p.m. Eastern Time on March 11, 1997. The Certificates will be
issued pursuant to a Pooling and Servicing Agreement, a form of which has been
filed as Exhibit 4.3 to the Registration Statement, to be entered into between
the Bank, as seller and servicer, and
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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 December 10,
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.
We consent to the filing of this opinion as an Exhibit to the Registration
Statement and to the reference to Shaw, Pittman, Xxxxx & Xxxxxxxxxx in the
Prospectus Supplement constituting a part of such Registration Statement under
the captions "Certain Federal Income Tax Considerations" and "Legal Matters."
Very truly yours,
/s/ Shaw, Pittman, Xxxxx & Xxxxxxxxxx
SHAW, PITTMAN, XXXXX & XXXXXXXXXX
