April 5, 2007                                       Mayer, Brown, Rowe & Maw LLP
                                                                 71 South Wacker
                                                    Chicago, Illinois 60606-4637

                                                         Main Tel (312) 782-0600
                                                         Main Fax (312) 701-7711
                                                          www.mayerbrownrowe.com

Residential Asset Mortgage Products, Inc.
8400 Normandale Lake Boulevard, Suite 250
Minneapolis, MN  55437

   Re: Mortgage Asset-Backed Pass-Through Certificates, Series 2007-SP1

Ladies and Gentlemen:

     We have advised Residential Asset Mortgage Products, Inc. (the
"Registrant") with respect to certain federal income tax aspects of the issuance
of the Mortgage Asset-Backed Pass-Through Certificates, Series 2007-SP1 (the
"Certificates"), which will be issued pursuant to a Pooling and Servicing
Agreement, dated as of March 1, 2007, as more particularly described in the
prospectus, dated December 4, 2006 (the "Base Prospectus"), and the prospectus
supplement, dated April 5, 2007 (the "Prospectus Supplement" and, together with
the Base Prospectus, the "Prospectus"), relating to such series, each forming a
part of the Registration Statement on Form S-3 (File No. 333-131211) as filed by
the Registrant with the Securities and Exchange Commission (the "Commission")
under the Securities Act of 1933, as amended (the "Act"), on January 20, 2006,
and declared effective on March 31, 2006 (the "Registration Statement").
Capitalized terms used but not defined herein have the meanings specified in the
Prospectus.

     The description of selected federal income tax consequences to holders of
the Certificates that appears under the heading "Material Federal Income Tax
Consequences" in the Base Prospectus and in the Prospectus Supplement does not
purport to discuss all possible income tax ramifications of the proposed
issuance, but with respect to those tax consequences which are discussed, in our
opinion such description is accurate in all material respects to the extent it
relates to matters of law or legal conclusions with respect thereto. In
addition, we adopt and confirm the statements in the description identified as
the opinion of special United States federal tax counsel.



  Berlin Brussels Charlotte Chicago Cologne Frankfurt Hong Kong Houston London
             Los Angeles New York Palo Alto Paris Washington, D.C.

          Mayer, Brown, Rowe & Maw LLP operates in combination with our
 associated English limited liability partnership in the offices listed above.



Residential Asset Mortgage Products, Inc.
April 5, 2007
Page 2


     We have examined such instruments, documents and records as we deemed
relevant and necessary as a basis of our opinion hereinafter expressed. In such
examination, we have assumed the following: (a) the authenticity of original
documents and the genuineness of all signatures; (b) the conformity to the
originals of all documents submitted to us as copies; (c) the truth, accuracy
and completeness of the information, representations and warranties contained in
the records, documents, instruments and certificates we have reviewed; (d) the
legal capacity of all natural persons; and (e) the authenticity of oral or
written statements and representations of public officials, officers and other
representatives of the Registrant and others.

                            [SIGNATURE PAGE FOLLOWS]






Residential Asset Mortgage Products, Inc.

     We hereby consent to the filing of this opinion letter as an exhibit to the
Registration Statement and to the use of our name wherever appearing in the
Prospectus contained therein. In giving such consent, we do not consider that we
are "experts," within the meaning of the term as used in the Act or the rules
and regulations of the Commission issued thereunder, with respect to any part of
the Registration Statement, including this opinion letter as an exhibit or
otherwise.

                                        Very truly yours,

                                        /s/ Mayer, Brown, Rowe & Maw LLP
                                        MAYER, BROWN, ROWE & MAW LLP