EXHIBIT 8     

DAVIS POLK & WARDWELL
450 LEXINGTON AVENUE
NEW YORK, NEW YORK 10017

October 2, 2003                         

LaSalle Funding LLC 135 South LaSalle Street Chicago, Illinois 60603 Ladies and Gentlemen:      We have acted as tax counsel to LaSalle Funding LLC, a limited liability company organized under the laws of Delaware, in connection with the preparation and filing of a prospectus supplement dated September 22, 2003 (the “Prospectus Supplement”) to a prospectus dated September 11, 2003, filed with the Securities and Exchange Commission as part of registration statement number 333-104778 on Form F-3 (the “Registration Statement”). This opinion is being furnished in accordance with the requirements of Item 601(b)(8) of Regulation S-K of the Securities Act of 1933, as amended (the “Act”).      We have reviewed the discussion contained under the heading “Certain United States Federal Income Tax Consequences” in the Prospectus Supplement and confirm that it sets forth in full our opinion as to the material U.S. federal income tax consequences of the purchase, ownership and disposition of the notes offered pursuant to the Prospectus Supplement, subject to the conditions and limitations set forth therein.      We hereby consent to the inclusion of this opinion and to the references to us under the heading “Certain United States Federal Income Tax Consequences” in the Prospectus Supplement. 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 Act.

Very truly yours, /s/ Davis Polk & Wardwell