<PAGE>

                                                                     EXHIBIT 5.1

April 16, 2003

Education Funding Capital I, LLC           Citigroup Global Markets Inc.,
Six East Fourth Street, Suite 300-A        as representative of the Underwriters
Cincinnati, Ohio 45202                     388 Greenwich Street, 35th Floor
                                           New York, New York 10013

Education Funding Capital Trust - II
c\o Fifth Third Bank
38 Fountain Square Plaza
Cincinnati, Ohio 45263

        Re:     Education Funding Capital Trust - II

Ladies and Gentlemen:

        We have acted as counsel to Education Funding Capital I, LLC, a Delaware
limited liability company (the "Depositor"), in connection with the Depositor's
Prospectus dated as of April 14, 2003 and the Prospectus Supplement dated as of
April 14, 2003 (together, the "Prospectus") with respect to the Series
A-1Education Loan Backed Notes, Series A-2 Education Loan Backed Notes, Series
A-3 Education Loan Backed Notes, Series A-4 Education Loan Backed Notes, Series
A-5 Education Loan Backed Notes, Series A-6 Education Loan Backed Notes, Series
A-7 Education Loan Backed Notes, Series A-8 Education Loan Backed Notes, and
Series B-1 Education Loan Backed Notes, (the "Notes") to be issued by Education
Funding Capital Trust - II, a Delaware statutory trust (the "Issuer").
Capitalized terms used but not defined herein shall have the definitions
assigned to such terms in the Prospectus. The Notes will be issued pursuant to
the Indenture of Trust dated as of April 1, 2003, as supplemented by the First
Supplemental Indenture of Trust dated as of April 1, 2003 (collectively, the
"Indenture") among the Issuer, Fifth Third Bank, as eligible lender trustee on
behalf of the Issuer (the "Eligible Lender Trustee") and Fifth Third Bank as
indenture trustee (the "Indenture Trustee").

        In the course of rendering this opinion, our review has been limited
solely to the following documents or certificates authenticated or certified to
our satisfaction:

        (i)     the Prospectus and Prospectus Supplement;

        (ii)    the Certificate of Formation and Limited Liability Company
                Agreement of the Depositor;

        (iii)   the Trust Agreement dated as of February 6, 2003 and the Amended
                and Restated Trust Agreement dated as of April 1, 2003, relating
                to the Issuer

<PAGE>

                among the Depositor, Wilmington Trust Company, not in its
                individual capacity but solely as Owner Trustee and Fifth Third
                Bank, not in its individual capacity but solely as Co-Owner
                Trustee (collectively, the "Trust Agreement");

        (iv)    the Indenture; and

        (v)     such other documents as we deemed necessary and appropriate
                under the circumstances.

        In such examination, we have assumed the genuineness of all signatures
(of parties other than the Depositor and the Issuer) on original documents and
the conformity to the original documents of all copies submitted to us. We have
also assumed the due execution and delivery by and enforceability against the
parties thereto (as to all parties other than the Depositor and the Issuer) of
all documents that we have examined where due execution and delivery or
enforceability is a prerequisite to the effectiveness thereof. As to various
facts material to our opinion, we have relied upon statements or certificates of
officers and representatives of the Depositor.

        Based upon the foregoing examinations and assumptions and subject to the
further assumptions, exceptions and qualifications set forth below, subject to
the further assumption that the Notes have been validly authorized and executed
by or on behalf of the Issuer, issued and authenticated in accordance with the
provisions of the Indenture and issued, delivered to and paid for by the
Underwriters in accordance with the provisions of the Underwriting Agreement
dated as of April 11, 2003 among Education Lending Group, Inc., the Depositor,
Education Lending Services, Inc., the Issuer and Citigroup Global Markets Inc.
as representative of the underwriters (the "Underwriting Agreement"), it is our
opinion that the Notes constitute valid and binding obligations of the Issuer
enforceable in accordance with their terms and entitled to the benefits of the
Indenture, except as follows:

                (A) the enforceability of the Notes and the Indenture may be
        limited by bankruptcy, insolvency, reorganization, moratorium,
        rearrangement, liquidation, conservatorship or other similar laws
        affecting creditors' rights generally, including court decisions
        interpreting such laws, statutes of limitations and personal
        jurisdiction;

                (B) the enforceability of the Notes and the Indenture and the
        availability of specific performance, injunctive relief and other forms
        of equitable relief are subject to principles of equity (regardless of
        whether such enforceability is considered in a proceeding in equity or
        at law); and

                (C) no opinion is expressed with respect to the enforceability
        of any provisions of the Notes or the Indenture that purport to require
        payment or reimbursement of attorneys' fees or litigation expenses of
        another party.

<PAGE>

        This opinion is provided as a legal opinion only. No opinion may be
inferred or implied beyond the matters expressly stated herein. This opinion is
solely for the benefit of the addressees set forth above. This opinion may be
relied upon by Fitch Ratings, Moody's Investors Service, Inc. and Standard &
Poor's. This opinion may not be relied upon in any manner or used by any other
person without our express written consent. This opinion speaks as of its date
only and we disclaim any undertaking or obligation to advise you of changes that
hereafter may come to our attention.

                                           Very truly yours,

                                           /s/ Thompson Hine LLP

                                           Thompson Hine LLP

PMS:RAS:SBS