Exhibit 5

                  OPINION OF LUSE GORMAN POMERENK & SCHICK, PC





                          LUSE GORMAN POMERENK & SCHICK
                           A PROFESSIONAL CORPORATION
                                ATTORNEYS AT LAW

                     5335 WISCONSIN AVENUE, N.W., SUITE 780
                             WASHINGTON, D.C. 20015
                            -------------------------
                            TELEPHONE (202) 274-2000
                            FACSIMILE (202) 362-2902
                                 www.luselaw.com

WRITER'S DIRECT DIAL NUMBER                                       WRITER'S EMAIL
(202) 274-2000


January 20, 2010

Board of Directors
Cullman Bancorp, Inc.
316 Second Avenue S.W.
Cullman, Alabama 35055

     Re:  Cullman Savings Bank Profit Sharing Plan
          Registration Statement on Form S-8
          ----------------------------------------

Ms. McClellan and Gentlemen:

     You have  requested  the  opinion  of this firm as to  certain  matters  in
connection  with the  registration  of  participation  interests  in the Cullman
Savings Bank Profit Sharing Plan (the "Plan").

     In rendering the opinion  expressed herein, we have reviewed the Charter of
Cullman  Bancorp,  Inc. (the  "Company"),  the Plan, 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:

     Upon the effectiveness of the Form S-8 and in accordance with the Plan, the
participation  interests in the Plan have been and will be legally issued, fully
paid and  non-assessable  and the shares of common  stock,  par value  $0.01 per
share, of the Company that may be purchased by the Plan will, upon purchase,  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

                                            LUSE GORMAN POMERENK & SCHICK
                                            A Professional Corporation