SWIDLER BERLIN SHEREFF FRIEDMAN, LLP

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July 29, 2002



AFL-CIO Housing Investment Trust
1717 K Street, N.W.
Suite 707
Washington, D.C.  20006

     Re:    AFL-CIO Housing Investment Trust,
            Units of Beneficial Interest

Ladies and Gentlemen:

     You have requested our opinion with respect to the legality of the
securities being registered pursuant to the Registration Statement on Form
N-1A (Registration No. 2-78066), Post-Effective Amendment No. 38 under the
Securities Act of 1933 and Amendment No. 41 under the Investment Company Act
of 1940 (collectively, the "Registration Statement").  At your request, this
opinion is being furnished as an exhibit to, and we consent to the filing of
it with, the Registration Statement.  In giving such permission, we do not
admit hereby that we come within the category of persons whose consent is
required under Section 7 of the Securities Act of 1933 or the rules or
regulations of the Securities and Exchange Commission thereunder.

     In rendering this opinion, we have reviewed the Declaration of Trust of
the AFL-CIO Housing Investment Trust ("Trust") and applicable judicial
decisions interpreting the laws of the District of Columbia with respect to
common law business trusts.  We have also reviewed the prospectus, statement
of additional information and statement of other information included in the
Registration Statement.  We assume, for purposes of this opinion, that Units
of Beneficial Interest in the Trust ("Units") will be issued at a price equal
to the net asset value per Unit, as described in the Registration Statement
and as determined as of monthly valuation dates and in accordance with the
procedures approved by the Board of Trustees pursuant to Section 2(a)(41)
under the Investment Company Act of 1940, as amended.




AFL-CIO Housing Investment Trust
July 29, 2002
Page 2


     Based upon the foregoing and upon such other investigation as we have
deemed necessary, we are of the opinion that, when offered and sold in
accordance with the Declaration of Trust and in the manner described in the
Registration Statement, the Units being registered under the Registration
Statement will when sold be legally issued, fully paid and non-assessable,
except that owners or holders of such Units may be liable for debts and other
obligations of the Trust in those states, such as, among others, Texas and
Kansas, that do not recognize so-called "business trusts" as separate legal
entities and hold beneficiaries of such trusts personally liable for actions
thereof.

                              Very truly yours,


                              SWIDLER BERLIN SHEREFF FRIEDMAN, LLP