EXHIBIT 5







(202) 274-2000

March 22, 2004

The Board of Directors
Atlantic Coast Federal Corporation
505 Haines Avenue
Waycross, Georgia 31501

               RE:    ATLANTIC COAST FEDERAL CORPORATION
                      COMMON STOCK PAR VALUE $0.01 PER SHARE
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Ladies and Gentlemen:

        You have requested the opinion of this firm as to certain matters in
connection with the offer and sale (the "Offering") of Atlantic Coast Federal
Corporation (the "Company") Common Stock, par value $0.01 per share ("Common
Stock"). We have reviewed the Company's Charter, Registration Statement on Form
S-1 (the "Form S-1"), as well as applicable statutes and regulations governing
the Company and the offer and sale of the Common Stock.

        We are of the opinion that upon the declaration of effectiveness of the
Form S-1, the Common Stock, when sold pursuant to the Company's prospectus and
the Atlantic Coast Federal Corporation Plan of Stock Issuance, will be legally
issued, fully paid and non-assessable.

        This Opinion has been prepared for the use of the Company in connection
with the Form S-1. We hereby consent to our firm being referenced under the
caption "Legal and Tax Opinions," and for inclusion as an exhibit to the
Registration Statement on Form S-1.

                                              Very truly yours,


                                              /s/ Luse Gorman Pomerenk & Schick
                                              ----------------------------------
                                              LUSE GORMAN POMERENK & SCHICK
                                              A PROFESSIONAL CORPORATION