A Practice Note discussing the role of opinion letters in California commercial real estate loans. Intended for both borrower's and lender's counsel, it offers guidance on drafting, reviewing, and negotiating real estate opinion letters in California. This Note describes a typical set of legal opinions delivered by California counsel in a commercial real estate loan transaction secured by real property in California. This Note also discusses common assumptions, qualifications, and exceptions often included in the opinion letter by the law firm rendering the legal opinion.