EX-8.1 3 ny20048209x2_ex8-1.htm EXHIBIT 8.1

Exhibit 8.1

          
 
TELEPHONE: 1-212-558-4000
FACSIMILE: 1-212-558-3588
WWW.SULLCROM.COM
125 Broad Street
New York, New York 10004-2498

LOS ANGELES • PALO ALTO • WASHINGTON, D.C.
 
BRUSSELS • FRANKFURT • LONDON • PARIS
 
BEIJING • HONG KONG • TOKYO
 
MELBOURNE • SYDNEY
   
   July 15, 2025



HomeStreet, Inc. and HomeStreet Bank
601 Union Street, Suite 2000
Seattle, WA 98101

Ladies and Gentlemen:

Reference is made to the Registration Statement on Form S-4 (as amended or supplemented through the date hereof, the “Registration Statement”) of HomeStreet, Inc., a Washington corporation (“HomeStreet”), including the proxy statement/prospectus/consent solicitation statement forming a part thereof, relating to the proposed transaction among HomeStreet, HomeStreet Bank and Mechanics Bank, a California banking corporation (“Mechanics”).

We have participated in the preparation of the discussion set forth in the section entitled “MATERIAL U.S. FEDERAL INCOME TAX CONSEQUENCES OF THE MERGER” in the Registration Statement.  In our opinion, such discussion of those consequences, insofar as it summarizes United States federal income tax law, and subject to the qualifications, exceptions, assumptions and limitations described therein, is accurate in all material respects.

We hereby consent to the filing of this opinion with the Securities and Exchange Commission as an exhibit to the Registration Statement, and to the references therein to us.  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 of 1933, as amended.

 
Very truly yours,
 
     
 
/s/ Sullivan & Cromwell