[MAUN & SIMON PLC LETTERHEAD]


                                       June 25, 1999



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


      Re:     American Church Mortgage Company ("ACMC")


Gentlemen:

     We have acted as counsel to you with respect to 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. In connection therewith, you have requested our opinion as to
whether the Company has been organized in conformity with the requirements
for qualification as a real estate investment trust, and whether its method
of operation will enable it to meet the requirements for qualification as a
real estate investment trust under the Internal Revenue Code of 1986, as
amended (the "Code").

     In rendering our opinion, we have examined certain documents, including:

          (a)   the Articles of Incorporation and Bylaws of the Company;

          (b)   the Advisory Agreement between the Company and Church Loan
     Advisors, Inc.;

          (c)   the Registration Statement, including exhibits to the
     Registration Statement; and

          (d)   such other certificates, opinions and instruments as we have
     deemed necessary.

As to various questions of fact which are material to the opinion set forth
in this letter, we have relied upon certain representations, statements and
information set forth in the foregoing documents and certificates of officers
of the Company and of public officials. In addition, we have assumed that the
business of the Company will be conducted as described in the Registration
Statement.


American Church Mortgage Company
June 25, 1999
Page 2


     As to matters of law, we have based our opinion upon the provisions of
the Code, the legislative history of the Code, the Treasury Department Income
Tax Regulations promulgated or proposed under the Code (the "Regulations"),
and the interpretations of the Code and the Regulations by the Internal
Revenue Service (the "Service") and by the courts as of the date of this
letter. The provisions of the Code or of the Regulations may be amended, or
the interpretations of the Service or of the courts may change in a manner
which would affect our opinions, and any such changes may have retroactive
effect.

     Based upon and subject to the foregoing, we are of the opinion that ACMC
is organized in conformity with the requirements for qualification as a real
estate investment trust and that its method of operation, as described in the
Prospectus, will enable it to meet the requirements for qualification and
taxation as a real estate investment trust under the Code.

     We are rendering no opinions regarding federal income tax matters other
than as expressly set forth in this letter. We consent to the use of this
opinion as an exhibit to the Registration Statement and to the reference to
our name under the headings "FEDERAL INCOME TAX MATTERS" and "LEGAL MATTERS"
in the Prospectus.

                            Very truly yours,

                            MAUN & SIMON, PLC


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


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