Exhibit 8.3




                         [Hunton & Williams' Letterhead]


                                 April 1, 1997




Deutsche Financial Capital
   Securitization LLC
7800 McCloud Road
Greensboro, North Carolina  27409-9636


Ladies and Gentlemen:

                  We have acted as counsel to Deutsche Financial Capital
Securitization LLC, a North Carolina limited liability company (the "Seller"),
in connection with the preparation of the Seller's Registration Statement on
Form S-3 (the "Registration Statement"), filed with the Securities and Exchange
Commission under the Securities Act of 1933, as amended (the "Act"), for the
registration under the Act of $500,000,000 aggregate principal amount of
Pass-Through Certificates (the "Certificates") representing interests in one or
more trusts (each a "Trust") to be established by the Seller. The Certificates
of each Trust will be issued pursuant to a form of Pooling and Servicing
Agreement, including Standard Terms thereto, among the Seller, a trustee to be
named therein, and Oakwood Acceptance Corporation, a North Carolina Corporation,
as servicer (a "Pooling and Servicing Agreement").

                  We have reviewed the originals or copies of (i) the Articles
of Association, Operating Agreement, and other organizational documents of the
Seller; (ii) certain resolutions of the Board of Directors of Deutsche Financial
Capital Securitization Corp., the manager of the Seller; (iii) the Pooling and
Servicing Agreement, including the forms of the Certificates annexed thereto;
(iv) the Registration Statement and the prospectus included therein; and (v)
such other documents as we have deemed necessary or appropriate as a basis for
the opinions set forth below.

                  Based on the foregoing, we are of the opinion that the legal
conclusions contained in the Registration Statement under the caption "Certain
Federal Income Tax Consequences" are correct in all material respects, and the
discussion thereunder does not omit any material provision with respect to the
matters covered. We also are of the opinion that, with respect to the issuance
of the Certificates of a Trust for which no election to be treated as a real
estate mortgage investment conduit is to be made, if (i) the







Deutsche Financial Capital
   Securitization LLC
April 1, 1997
Page 2

Seller, the Trustee, and the other parties to the issuance transaction comply
(without waiver) with all of the provisions of the 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 be classified as a grantor trust under
Subpart E, Part 1 of subchapter J of the Internal Revenue Code of l986, 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 under the caption "Certain 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
North Carolina or any other state.

                                                     Very truly yours,



                                                     /s/ Hunton & Williams