EXHIBIT 8.3

                         [Letterhead of Hunton & Williams LLP]

                                  July 22, 2004

Origen Residential Securities, Inc.
27777 South Franklin Road
Suite 1700
Southfield, Michigan  48034

Ladies and Gentlemen:

      We have acted as counsel to Origen Residential Securities, Inc., a
Delaware corporation (the "Company"), in connection with the Company's
Registration Statement on Form S-3 (the "Registration Statement"), filed on the
date hereof with the Securities and Exchange Commission under the Securities Act
of 1933, as amended (the "Act"), for the registration under the Act of
collateralized notes ("Notes") or pass-through certificates (the
"Certificates"), issuable in one or more series by separate trusts (each, a
"Trust") to be established by the Company. The Certificates of each Trust will
be issued pursuant to the form of pooling and servicing agreement, among the
Company, the trustee to be named therein (the "Trustee"), Origen Servicing,
Inc., as servicer and seller, Origen Financial L.L.C., as loan originator, and,
if required, a back-up servicer to be named therein (the "Pooling and Servicing
Agreement").

      We have reviewed the originals or copies of (i) the Pooling and Servicing
Agreement, including the forms of the Certificates annexed thereto; (ii) the
Registration Statement, the prospectus and the related prospectus supplement
included therein; and (iii) such other documents as we have deemed necessary or
appropriate as a basis for the opinions set forth below.

      Based on the foregoing, we adopt and confirm that the legal conclusions
contained in the Registration Statement under the caption "Material Federal
Income Tax Consequences" are our opinion as to the material federal income tax
consequences associated with the purchase, ownership and disposition of the
Certificates. We also are of the opinion that, with respect to the issuance of
the Certificates for which no election to be treated as a real estate mortgage
investment conduit is to be made, if (i) the Company, the Trustee, and the other
parties to the issuance transaction comply (without waiver) with all of the
provisions of the applicable Pooling and Servicing Agreement and certain other
documents to be prepared and executed in connection with such transaction and
(ii) the Certificates are issued and sold as described in the Registration
Statement and the prospectus supplement to be issued in connection with the
Trust, the Trust will



Origen Residential Securities, Inc.
July 22, 2004
Page 2

be classified as a grantor trust under Subpart E, Part 1 of subchapter J of the
Internal Revenue Code of 1986, as amended (the "Code"), and not as an
association taxable as a corporation.

      You should be aware that the above opinions represent our conclusions as
to the application of existing law to the transaction described above. There can
be no assurance that contrary positions will not be taken by the Internal
Revenue Service or that the law will not change.

     We hereby consent to the filing of this opinion as an exhibit to the
Registration Statement. We also consent to the references to Hunton & Williams
LLP under the caption "Material Federal Income Tax Consequences" in the
Prospectus. In giving this consent, we do not admit that we are in the category
of persons whose consent is required by Section 7 of the Act or the rules and
regulations promulgated thereunder by the Securities and Exchange Commission.

      No opinion has been sought and none has been given concerning the tax
treatment of the issuance and sale of the Certificates under the laws of any
state.

                                                     Very truly yours,

                                                     /s/ Hunton & Williams LLP

                  [H&W Tax Opinion re: Non-REMIC Certificates]