Exhibit 8.1

                                  April 7, 2005


Consumer Portfolio Services, Inc.
16355 Laguna Canyon Road
Irvine, California  92618

         Re:      Registration Statement on Form S-2 (No. 333-121913)
                  Renewable Unsecured Subordinated Notes

Ladies and Gentlemen:

         We are acting as counsel for Consumer Portfolio Services, Inc. (the
"Company") in connection with a public offering of up to $100,000,000 aggregate
principal amount of its renewable Unsecured Subordinated Notes (the "Notes"), to
be issued under an indenture (the "Indenture") to be entered into between the
Company and Wells Fargo Bank, National Association (the "Trustee").

         In connection with this opinion, we have examined originals or copies,
certified or otherwise identified to our satisfaction, of (i) the Registration
Statement of the Company on Form S-2 relating to the Notes, filed with the
Securities and Exchange Commission (the "Commission") on January 7, 2005 under
the Securities Act, as amended by Amendment No. 1 thereto to be filed with the
Commission on or about April 7, 2005 (such Registration Statement being
hereafter referred to as the "Registration Statement"); (ii) the form of the
Indenture relating to the Notes to be entered into by the Company and the
Trustee, to be filed as an exhibit to the Registration Statement; (iii) the
Articles of Incorporation of the Company, as presently in effect, incorporated
by reference to the Registration Statement; and (iv) the form of the Notes. We
have also examined originals or copies, certified or otherwise identified to our
satisfaction, of such records of the Company and such agreements, certificates
of public officials, certificates of officers or other representatives of the
Company and others, and such other documents, certificates and records as we
have deemed necessary or appropriate as a basis for the opinions set forth
herein.







Consumer Portfolio Services, Inc.
April 7, 2005
Page 2


         In our examination, we have assumed the legal capacity of all natural
persons, the genuineness of all signatures, the authenticity of all documents
submitted to us as originals, the conformity to original documents of all
documents submitted to us as certified, conformed or photostatic copies and the
authenticity of the originals of such latter documents. In making our
examination of documents executed or to be executed by parties other than the
Company, we have assumed that such parties had or will have the power, corporate
or other, to enter into and perform all obligations thereunder and have also
assumed the due authorization by all requisite action, corporate or other, and
execution and delivery by such parties of such documents and the validity and
binding effect thereof. As to any facts material to the opinion expressed herein
which we have not independently established or verified, we have relied upon
statements and representations of officers and other representatives of the
Company and others.

         On the basis of the foregoing and subject to the limitations and
qualifications set forth below, the description of federal income tax
consequences appearing under the heading "Material Federal Income Tax
Consequences" in the prospectus contained in the Registration Statement is our
opinion of the material federal income tax consequences to holders of the Notes
under existing law and subject to the qualifications and assumptions stated
therein.

         The opinion herein is based upon our interpretations of current law,
including court authority and existing Final and Temporary Regulations, which
are subject to change both prospectively and retroactively, and upon the facts
and assumptions discussed herein. This opinion letter is limited to the matters
set forth herein, and no opinions are intended to be implied or may be inferred
beyond those expressly stated herein. Our opinion is rendered as of the date
hereof and we assume no obligation to update or supplement this opinion or any
matter related to this opinion to reflect any change of fact, circumstances, or
law after the date hereof. In addition, our opinion is based on the assumption
that the matter will be properly presented to the applicable court. Furthermore,
our opinion is not binding on the Internal Revenue Service or a court. In
addition, we must note that our opinion represents merely our best legal
judgment on the matters presented and that others may disagree with our
conclusion. There can be no assurance that the Internal Revenue Service will not
take a contrary position or that a court would agree with our opinion if
litigated.

         We consent to the use and filing of this opinion as Exhibit 8.1 to the
Registration Statement and to the reference to our firm under the caption "Legal
Matters" in the Prospectus contained therein. In giving such consent we do not
imply or admit that we are within the category of persons whose consent is
required under Section 7 of the 1933 Act or the rules and regulations of the
Securities and Exchange Commission thereunder.

                                Very truly yours,

                                /S/ ANDREWS KURTH LLP
                                ---------------------
                                ANDREWS KURTH LLP