8-K

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                       SECURITIES AND EXCHANGE COMMISSION

                             Washington, D.C. 20549

                                    Form 8-K

                                 CURRENT REPORT

                     Pursuant to Section 13 or 15(d) of the
                         Securities Exchange Act of 1934

       Date of Report (Date of earliest event reported) December 11, 2001


                            CHEVY CHASE BANK, F.S.B.
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             (Exact name of registrant as specified in its charter)



          United States                   333-71668              52-0897004
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(State or Other Jurisdiction of       (Commission File        (I.R.S. Employer
         Incorporation)                    Number)           Identification No.)


           7501 Wisconsin Avenue
         Bethesda, Maryland 20814                                 20814
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     (Address of Principal Executive                            (Zip Code)
                 Offices)


        Registrant's telephone number, including area code (301) 986-7000
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                                    No Change
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          (Former name or former address, if changed since last report)


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 Item 7.     Financial Statements, Pro Forma Financial Information and Exhibits.
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 (a)      Not applicable

 (b)      Not applicable

 (c)      Exhibits:


             8.1  Opinion of Dewey Ballantine LLP regarding certain tax matters.




                                   SIGNATURES

          Pursuant to the requirements of Section 13 or 15(d) of the Securities
Exchange Act of 1934, the registrant has duly caused this Report to be signed on
its behalf by the undersigned thereunto duly authorized.

                              CHEVY CHASE BANK, F.S.B., on behalf of Chevy Chase
                              Auto Receivables Trust 2001-3

                              Registrant



                              By:    /s/ Mark A. Holles
                                     ------------------
                              Name:  Mark A. Holles
                              Title: Group Vice President



Dated:  December 11, 2001



                                  EXHIBIT INDEX

Exhibit No.     Description
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Exhibit 8.1     Opinion of Dewey Ballantine LLP regarding certain tax matters.

EX-8.1

                                December 11, 2001


To the Addressees Listed
on Schedule One


          Re:  Chevy Chase Auto Receivables Trust 2001-3
               -----------------------------------------


Ladies and Gentlemen:

          We have acted as tax counsel to Chevy Chase Bank, F.S.B., a federally
chartered stock savings bank ("Chevy Chase"), and Chevy Chase Auto Receivables
Trust 2001-3 (the "Trust"), as to certain matters in connection with the
issuance and sale of the Class A-1 2.0375% Asset Backed Notes, Class A-2 2.88%
Asset Backed Notes, Class A-3 3.95% Asset Backed Notes, and Class B 4.70% Asset
Backed Notes (collectively, the "Notes") issued under an Indenture, dated as of
December 1, 2001 (the "Indenture") between the Trust and U.S. Bank National
Association, as indenture trustee (the "Indenture Trustee") and a certificate
(the "Certificate") which will be issued pursuant to a Trust Agreement, dated as
of November 1, 2001, as amended and restated by an Amended and Restated Trust
Agreement, dated as of December 13, 2001 (the "Trust Agreement"), between Chevy
Chase and Wilmington Trust Company (the "Owner Trustee"). Capitalized terms not
otherwise defined herein have their respective meanings as set forth in the
Indenture.

          In such role, we have reviewed such documents as we have deemed
appropriate for the purposes of rendering the opinions set forth below. In
addition, in conducting our analysis we have relied on certain representations
made to us by Chevy Chase and their underwriter.

          We have examined the question of whether the Notes issued under the
Indenture will constitute indebtedness for federal income tax purposes. Our
analysis is based on the provisions of the Internal Revenue Code of 1986, as
amended (the "Code") and the Treasury regulations promulgated thereunder as in
effect on the date hereof and on existing judicial and administrative
interpretations thereof. These authorities are subject to change and to
differing interpretations, which could apply retroactively. The opinion of tax
counsel is not binding on the courts or the Internal Revenue Service (the
"IRS").

          In general, whether a transaction constitutes the issuance of
indebtedness for federal income tax purposes is a question of fact, the
resolution of which is based primarily upon



To the Addressees Listed
 on Schedule One
December 11, 2001
Page 2


the economic substance of the instruments and the transaction pursuant to which
they are issued rather than the form of the transaction or the manner in which
the instruments are labeled. The IRS and the courts have set forth various
factors to be taken into account in determining whether or not a transaction
constitutes the issuance of indebtedness for federal income tax purposes, which
we have reviewed as they apply to this transaction.

          Based on the foregoing, and such legal and factual investigations as
we have deemed appropriate, while no transaction closely comparable to that
contemplated has been the subject of any Treasury regulation, revenue ruling or
judicial decision, and therefore the matter is subject to interpretation, we are
of the opinion that for federal income tax purposes:

          (1)  The Notes will be treated as indebtedness because: (i) the
     characteristics of the transaction strongly indicate that, in economic
     substance, the transaction is the issuance of indebtedness; (ii) the form
     of the transaction is an issuance of indebtedness; and (iii) the parties
     have stated unambiguously their intention to treat the transaction as the
     issuance of indebtedness for tax purposes.

          (2)  Assuming compliance with the terms of the Trust Agreement and the
     related documents, the Trust will not be an association or a publicly
     traded partnership taxable as a corporation.

          We express no opinion on any matter not discussed in this letter. This
opinion is rendered as of the Closing Date, for the sole benefit of the
addressees hereof and it may not be relied on by any other party or quoted
without our express consent in writing. We consent to the use of our name and
the reference to this opinion under the heading "Material Federal Income Tax
Considerations" in the Prospectus Supplement relating to the Notes.


                                        Very truly yours,

                                        /s/ Dewey Ballantine LLP



                                  SCHEDULE ONE

Chevy Chase Auto Receivables
Trust 2001-3
c/o Wilmington Trust Company,
Rodney Square North
1100 North Market Street
Wilmington, DE 19890-0001

Chevy Chase Bank, F.S.B.
7501 Wisconsin Avenue
Bethesda, MD 20814

U.S. Bank National Association
180 East 5th Street
St. Paul, MN 55101

Credit Suisse First Boston Corporation,
as Representative of the Underwriters
11 Madison Avenue, 5th Floor
New York, NY 10010

Moody's Investors Service
99 Church Street
New York, NY 10007

Standard & Poor's Ratings Services,
A Division of The McGraw-Hill Companies
55 Water Street
New York, NY 10041

Fitch, Inc.
One State Street Plaza
New York, NY