EXHIBIT 8.1

            [Letterhead of Skadden, Arps, Slate, Meagher & Flom LLP]



                                             June 29, 2004



North Fork Bancorporation, Inc.
275 Broad Hollow Road
Melville, New York 11747

Ladies and Gentlemen:

            We have acted as counsel to North Fork Bancorporation, Inc., a
Delaware corporation ("NF"), in connection with the proposed merger (the
"Merger") under the laws of the State of Delaware of GreenPoint Financial Corp.,
a Delaware corporation ("Company") with and into NF, pursuant to the Agreement
and Plan of Merger (the "Agreement"), dated as of February 15, 2004, between NF
and the Company. This opinion is being delivered in connection with the joint
proxy statement-prospectus that was included in the Registration Statement of NF
on Form S-4 (the "Registration Statement") filed with the Securities and
Exchange Commission (the "Commission") under the Securities Act of 1933, as
amended (the "Securities Act"), and in accordance with the requirements of Item
601(b)(8) of Regulation S-K under the Securities Act.(1)

            In rendering our opinion set forth below, we have examined and
relied upon the accuracy and completeness (without, as you are aware, our
independent investigation or verification), both initially and continuing as of
the Effective Time, of the facts, information, representations, covenants and
agreements contained in originals or copies, certified or otherwise identified
to our satisfaction, of the Agreement, the Registration Statement and such other
documents as we have deemed necessary or appropriate as a basis for the opinion
set forth below. In addition, we have relied upon the accuracy and completeness,
both initially and continuing as of the Effective Time, of certain statements,
representations, covenants and agreements made by NF, the Company and others,
including factual statements and representations set forth in letters dated the
date hereof from officers of NF and the Company (the "Representation Letters").
For purposes of rendering our opinion, we have assumed that such statements,
representations, covenants and agreements are, and will continue to be as of the
Effective Time, true and correct without regard to any qualification as to
knowledge or belief. Our


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(1)   Unless otherwise indicated, all defined terms used herein shall have the
      meanings assigned to them in the Agreement.

opinion assumes and is expressly conditioned on, among other things, the initial
and continuing accuracy and completeness of the facts, information,
representations, covenants and agreements set forth in the documents referred to
above and the statements, representations, covenants and agreements made by NF
and the Company, including those set forth in the Representation Letters, and we
have assumed that the Representation Letters will be re-executed by appropriate
officers as of the Effective Time.

            In our examination, we have assumed the genuineness of all
signatures, the legal capacity of natural persons, the authenticity of all
documents submitted to us as originals, the conformity to original documents of
all documents submitted to us as certified or photostatic copies, and the
authenticity of the originals of such documents. We also have assumed that the
transactions related to the Merger or contemplated by the Agreement will be
consummated in accordance with the Agreement and as described in the
Registration Statement, and that none of the terms and conditions contained
therein will have been waived or modified in any respect prior to the Effective
Time.

            In rendering our opinion, we have considered applicable provisions
of the Internal Revenue Code of 1986, as amended (the "Code"), Treasury
Regulations promulgated thereunder (the "Regulations"), pertinent judicial
authorities, rulings of the Internal Revenue Service and such other authorities
as we have considered relevant, in each case, in effect on the date hereof. It
should be noted that such laws, Code, Regulations, judicial decisions,
administrative interpretations and such other authorities are subject to change
at any time and, in some circumstances, with retroactive effect. A change in any
of the authorities upon which our opinion is based, or any variation or
difference in any fact from those set forth or assumed herein or in the
Registration Statement, the Agreement or the Representation Letters, could
affect our conclusions herein. Moreover, there can be no assurance that our
opinion will be accepted by the Internal Revenue Service or, if challenged, by a
court.

            Based solely upon and subject to the foregoing, we are of the
opinion that under current law, the Merger will be treated for federal income
tax purposes as a reorganization within the meaning of Section 368(a) of the
Code.

            Except as set forth above, we express no opinion to any party as to
the tax consequences, whether federal, state, local or foreign, of the Merger or
of any transactions related thereto or contemplated by the Agreement. We
disclaim any undertaking to advise you of any subsequent changes of the facts
stated or assumed herein or any subsequent changes in applicable law.

            In accordance with the requirements of Item 601(b)(23) under the
Securities Act, we hereby consent to the filing of this opinion as Exhibit 8.1
to the Registration Statement. We also consent to the use of our name under the
heading "Legal Matters" in the Registration Statement. 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 Securities Act or the rules and regulations of
the Commission thereunder.


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                              Very truly yours,


                              /s/ Skadden, Arps, Slate, Meagher & Flom LLP


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