EXHIBIT 5


                        [MAUN & SIMON PLC LETTERHEAD]


                                    June 25, 1999


American Church Mortgage Company
10237 Yellow Circle Drive
Minnetonka, MN 55343


       Re:     American Church Mortgage Company


Gentlemen:

     We have acted as counsel to you in connection with the preparation and
filing by you of a Registration Statement on Form S-11 (the "Registration
Statement"), containing a Prospectus (the "Prospectus"), under the Securities
Act of 1933, as amended (the "Act"), with respect to the registration of
1,650,000 shares of common stock, with a par value of $.01 per share (the
"Shares"), of American Church Mortgage Company ("ACMC"), a Minnesota
corporation. We have examined such documents, records and matters of law as
we have deemed necessary for purposes of this opinion and, based thereon, we
are of the opinion that the Shares are duly and validly authorized for
issuance and, when issued and paid for, as described in the Prospectus, will
be validly issued, fully paid and nonassessable.

     We consent to the use of this opinion as an exhibit to the Registration
Statement and to the reference to our name under the heading "LEGAL MATTERS"
in the Prospectus. In giving such consent, we do not hereby admit that we
come within the category of persons whose consent is required under Section 7
of the Act or the Rules and Regulations of the Securities and  Exchange
Commission promulgated under the Act.

                                       Very truly yours,

                                       MAUN & SIMON, PLC

                                       By:  /s/ Philip T. Colton
                                            -----------------------------------
                                            Philip T. Colton, a Member

PTC:cr