Exhibit 5

                  [LETTERHEAD OF LUSE GORMAN POMERENK & SCHICK]


(202) 274-2000

July 25, 2005

Board of Directors
Atlantic Coast Federal Corporation
505 Haines Avenue
Waycross, Georgia 31501

                  Re:      Atlantic Coast Federal Corporation
                           Registration Statement on Form S-8
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Gentlemen:

     You have  requested  the  opinion  of this firm as to  certain  matters  in
connection with the registration of common stock, par value $0.01 per share (the
"Common Stock"),  of Atlantic Coast Federal  Corporation (the "Company")  issued
pursuant to the Atlantic  Coast Federal  Corporation  2005 Stock Option Plan and
the Atlantic  Coast Federal  Corporation  2005  Recognition  and Retention  Plan
(together, the "Plans").

     In rendering the opinion  expressed herein, we have reviewed the Charter of
the Company,  the Plans, the Company's  Registration  Statement on Form S-8 (the
"Form S-8"),  as well as  applicable  statutes  and  regulations  governing  the
Company.  We have assumed the  authenticity,  accuracy and  completeness  of all
documents in connection with the opinion  expressed herein. We have also assumed
the legal  capacity and  genuineness  of the  signatures of persons  signing all
documents in connection with which the opinions expressed herein are rendered.

     Based on the foregoing, we are of the following opinion:

     At the time of  effectiveness  of the Form  S-8,  the  Common  Stock of the
Company,  when issued in accordance  with the terms and conditions of the Plans,
will be legally issued, fully paid and non-assessable.

     This  opinion  has  been  prepared  solely  for the use of the  Company  in
connection  with the  preparation  and filing of the Form S-8, and should not be
used for any other purpose or relied upon by any other person  without the prior
written  consent of this firm.  We hereby  consent to the use of this opinion in
the Form S-8.

                                        Very truly yours,


                                        /s/ Luse Gorman Pomerenk & Schick, P.C.
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                                        Luse Gorman Pomerenk & Schick
                                        A Professional Corporation