JONES & KELLER, P.C.
                      1625 Broadway, Suite 1600
                       Denver, Colorado  80202
                           (303) 573-1600


                            May 28, 1999



Factual Data Corp.
5200 Hahns Peak Drive
Loveland, Colorado  80538

Gentlemen:

      You have  requested  our  opinion  in  connection  with  the  Registration
Statement on Form S-8 (the "Registration  Statement") of Factual Data Corp. (the
"Corporation"),  relating  to the offer and sale of up to 200,000  shares of the
Common  Stock of the  Corporation  (the  "Common  Stock")  under the 1997  Stock
Incentive  Plan  approved by the  Corporation's  Board of  Directors  and by the
Corporation's  shareholders  (the "Plan").  In connection with your request,  we
have made such  examinations  of the corporate  records and  proceedings  of the
Corporation  and considered  such questions of law and taken such further action
as we deemed necessary or appropriate to enable us to render this opinion.

      Based upon such  examination,  we are of the opinion  that when the Common
Stock  has been  purchased  and the  purchase  price  therefor  has been paid as
described  in the  Plan  and the  Registration  Statement,  as the  same  may be
amended,  and when the Corporation has complied with the Securities Act of 1933,
as amended,  and with the securities laws of the State of Colorado and all other
jurisdictions  in which Common  Stock is to be sold  pursuant to the exercise of
stock options  granted under the Plan, the Common Stock will be legally  issued,
fully paid and non-assessable.

      We consent to the filing of this opinion as Exhibit 5 to the  Registration
Statement.  In giving this consent,  however, we do not admit that we are in the
category of persons whose consent is required  under Section 7 of the Securities
Act of  1933  or the  Rules  and  Regulations  of the  Securities  and  Exchange
Commission thereunder.

                                    Very truly yours,

                                    JONES & KELLER, P.C.

                                    /s/ Samuel E. Wing