Exhibit (i)(1)

                                 April 29, 2009

AFL-CIO Housing Investment Trust
2401 Pennsylvania Avenue, N.W., Suite 200
Washington, D.C. 20037

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

Ladies and Gentlemen:

      We have  acted as counsel  to the  AFL-CIO  Housing  Investment  Trust,  a
District of Columbia  common law trust (the  "Trust"),  on behalf of its series,
Series A - AFL-CIO Housing Investment Trust (the "Fund"), in connection with the
Trust's  Post-Effective  Amendment No. 53 under the  Securities  Act of 1933, as
amended,  and  Amendment  No. 56 under the  Investment  Company Act of 1940,  as
amended,  to the Trust's  Registration  Statement  on Form N-1A,  filed with the
Securities  and  Exchange  Commission  on  April  29,  2009  (collectively,  the
"Registration  Statement"),  with respect to the Units of Beneficial Interest in
the Fund (the "Units").

      In connection with this opinion,  we have examined the following described
documents:

      (a) the prospectus,  statement of additional  information and statement of
other information included in the Registration Statement;

      (b) a copy of the Trust's  Declaration of Trust and each amendment thereto
(the "Declaration"); and

      (c) a certificate executed by the General Counsel of the Trust, certifying
as to, and attaching copies of, the Declaration, the Trust's By-Laws and certain
votes of the Trustees of the Trust (the "Resolutions").

      In such  examination,  we have assumed the  genuineness of all signatures,
the  conformity  to the  originals  of all of the  documents  reviewed  by us as
copies,  the authenticity  and  completeness of all documents  reviewed by us in
original or copy form and the legal competence of each individual  executing any
document.  We have also  assumed that the Trust's  Declaration,  By-Laws and the
Resolutions  will not have been amended,  modified or withdrawn  with respect to
matters  relating  to the Units and will be in full force and effect on the date
of the issuance of such Units. We have made no other review or  investigation of



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any kind  whatsoever,  and we have assumed,  without  independent  inquiry,  the
accuracy of the information set forth in such documents.

      This  opinion is limited  solely to the internal  substantive  laws of the
District of Columbia (other than the District of Columbia securities laws, as to
which we express no opinion) as applied by courts in the District of Columbia to
the extent such laws may apply to or govern the matters covered by this opinion.
In addition,  to the extent that the Trust's  Declaration  or By-Laws  refer to,
incorporate or require  compliance  with the Investment  Company Act of 1940, as
amended, or any other law or regulation  applicable to the Trust, except for the
internal  substantive  laws of the District of Columbia,  as aforesaid,  we have
assumed  compliance  by the  Trust  with  such  Act  and  such  other  laws  and
regulations.

      We understand  that all of the foregoing  assumptions  and limitations are
acceptable to you.

      Based  upon  and   subject  to  the   foregoing   and,   upon  such  other
investigations  as we have deemed  necessary,  please be advised  that it is our
opinion  that the Units,  when  issued and sold in  accordance  with the Trust's
Declaration and By-Laws and for the consideration  described in the Registration
Statement, will be validly issued, fully paid and nonassessable, except that, as
set forth in the  Registration  Statement,  owners or holders of Units may under
certain circumstances be held personally liable for the Trust's obligations.

      We hereby  consent  to the  filing of this  opinion  as an  exhibit to 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, as amended,  or the rules or regulations of the
Securities and Exchange Commission thereunder.


                                    Very truly yours,

                                    /s/ BINGHAM MCCUTCHEN LLP