[On Nixon Peabody LLP Letterhead] 1255 23rd Street, N.W. Washington, DC 20037-1170 (202) 973-7700 Fax: (202) 973-7750 Direct Dial: (202) 973-7700 December ______, 1999 Board of Directors Eagle Bancorp 1400 Prospect Avenue Helena, MT 59604 Re: Registration Statement Under the Securities Act of 1933 Board Members: This opinion is rendered in connection with the Registration Statement on Form SB-2 to be filed with the Securities and Exchange Commission under the Securities Act of 1933 relating to the offer and sale of up to 1,010,059 shares of common stock, par value $0.01 per share (the "Common Stock"), of Eagle Bancorp (the "Company"), including shares to be issued to certain employee benefit plans of the Company and its subsidiary. The Common Stock is proposed to be issued pursuant to the Amended and Restated Plan of Mutual Holding Company Reorganization and Stock Issuance (the "Plan") of American Federal Savings Bank (the "Bank") in connection with the Bank's reorganization from a mutual savings bank form of organization to a mutual savings bank holding company form of organization, whereby the Bank will convert to the stock form of organization and become a wholly owned subsidiary of the Company. The mutual holding company, Eagle Financial MHC (in organization) (the "MHC"), will own a majority of the shares of the Company, and a minority of the shares of the Company are to be offered and sold to the public. As special counsel to the Bank, the MHC and the Company, we have reviewed the corporate proceedings relating to the Plan and the Reorganization and such other legal matters as we have deemed appropriate for the purpose of rendering this opinion. Based on the foregoing, we are of the opinion that the shares of Common Stock covered by the aforesaid Registration Statement will, when issued in accordance with the terms of the Plan against full payment therefor, be validly issued, fully paid, and non-assessable shares of common stock of the Company. We assume no obligation to advise you of changes that may hereafter be brought to our attention. We hereby consent to the use of this opinion and to the reference to our firm appearing in the Company's Prospectus under the headings "The Reorganization - Federal and State Tax Consequences of the Reorganization" and "Legal and Tax Opinions." We also consent to any references to our legal opinion referred to under the aforementioned headings in the Prospectus. Very truly yours, D R A F T Nixon Peabody LLP