EXHIBIT 8.3



                                                               September 4, 1998


Board of Directors
Revere Federal Savings and Loan Association
310 Broadway
Revere, Massachusetts 02151


Re:  Plan of Conversion Subscription Rights

Gentlemen:

     All  capitalized  terms  not  otherwise  defined  in this  letter  have the
meanings  given  such  terms  in the  Plan of  Reorganization  and Plan of Stock
Issuance  adopted by the Board of Directors of Revere  Federal  Savings and Loan
Association  ("Revere  Federal"  or  the  "Bank").   Pursuant  to  the  Plan  of
Reorganization  and  Plan of  Stock  Issuance,  Revere  Federal  will  become  a
wholly-owned  subsidiary of RFS Bancorp, Inc. (the "Holding Company"), a Federal
corporation,  and RFS Bancorp, Inc. will issue a majority of its common stock to
Revere, MHC (the "MHC"), and sell a minority of its common stock to the public.

     We understand that in accordance with the Plan of  Reorganization  and Plan
of Stock Issuance  subscription rights to purchase shares of Common Stock in the
Holding Company are to be issued to: (1) Eligible Account Holders; (2) the ESOP;
(3) Supplemental  Eligible Account Holders; and (4) Other Members.  Based solely
upon our  observation  that the  subscription  rights will be  available to such
parties  without cost, will be legally  non-transferable  and of short duration,
and will afford such  parties the right only to purchase  shares of Common Stock
at the same  price  as will be paid by  members  of the  general  public  in the
Community  Offering,  but without  undertaking any independent  investigation of
state or federal  law or the  position  of the  Internal  Revenue  Service  with
respect to this issue, we are of the belief that, as a factual matter:

     (1)  the subscription rights will have no ascertaninable market value; and,

     (2)  the price at which the subscription rights are exercisable will not be
          more or less  than  the pro  forma  market  value of the  shares  upon
          issuance.

     Changes in the local and national  economy,  the legislative and regulatory
environment,  the stock market,  interest rates, and other external forces (such
as natural  disasters or significant  world events) may occur from time to time,
often with great  unpredictability and may materially impact the value of thrift
stocks  as a  whole  or the  Holding  Company's  value  alone.  Accordingly,  no
assurance  can be given that persons who  subscribe to shares of Common Stock in
the Subscription  Offering will thereafter be able to buy or sell such shares at
the same price paid in the Subscription Offering.

                                                           Very truly yours,

                                                           RP FINANCIAL, L.C.


                                                           James J. Oren
                                                           Senior Vice President