[Hunton & Williams Letterhead]

                                                      File Number:  52444.000002
                                                      Direct Dial:  804/788-8200

                                                                     Exhibit 8.2

                                August 14, 1998

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 $100,000,000 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 I 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.





Deutsche Financial Capital
   Securitization LLC
August 14, 1998
Page 2

         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 an election to be treated as a real
estate mortgage investment conduit ("REMIC") is to be made, if (i) the 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, (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, and (iii) an election is properly made and filed for the Trust
(or designated assets thereof) to be treated as one or more REMICs pursuant to
Section 860D of the Internal Revenue Code of 1986, as amended (the "Code"), the
Trust (or designated assets thereof) will qualify as one or more REMICs, and the
Certificates relating to the Trust will be considered to be "regular interests"
or the "residual interest" in a REMIC (as designated in the relevant prospectus
supplement) on the date of issuance thereof and thereafter, assuming continuing
compliance with the REMIC provisions of the Code and any regulations thereunder.

         You should be aware that the above opinions represent our conclusions
as to the application of existing law to a transaction as 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.





Deutsche Financial Capital
   Securitization LLC
August 14, 1998
Page 3

         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