1

                        [Letterhead of McConnell Valdes]
                                                                     EXHIBIT 8.0

                               February 16, 2001

Board of Directors
R&G Financial Corporation
280 Jesus T. Pinero Avenue
Hato Rey, Puerto Rico 00918

         Re: Registration Statement on Form S-3

Ladies and Gentlemen:

         As special Puerto Rico tax counsel to R&G Financial Corporation (the
"Issuer") in connection with the issuance by the Issuer of up to 2,300,000
shares of ___% Noncumulative Perpetual Monthly Income Preferred Stock, Series C
Preferred Stock pursuant to the prospectus (the "Prospectus") contained in the
Registration Statement, we hereby confirm to you that our opinion set forth
under the heading "Puerto Rico Taxation" in the Prospectus, subject to the
limitations set forth therein, is an accurate discussion of the principal Puerto
Rico tax consequences to the investors who purchase the securities in the
offering described in the Prospectus.

         We hereby consent to the filing of this opinion as an exhibit to the
Registration Statement and to any reference to us under the heading "Legal
Matters" in the Prospectus. In giving such consent, we do not thereby admit that
we are in the category of persons whose consent is required under Section 7 of
the Act.

                                            Very truly yours,


                                            /s/ MCCONNELL VALDES
                                            -----------------------------
                                            McCONNELL VALDES