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