January 24, 2000




Citicorp Mortgage Securities, Inc.
12855 North Outer Forty Drive
St. Louis, MO  63141

                  Re:      Citicorp Mortgage Securities, Inc.
                           REMIC Pass-Through Certificates, Series 2000-1
                           ----------------------------------------------

Ladies and Gentlemen:

                  We have acted as special tax counsel to Citicorp Mortgage
Securities, Inc., a Delaware corporation (the "Company"), in connection with the
issuance of certificates designated as Citicorp Mortgage Securities, Inc. REMIC
Pass-Through Certificates, Series 2000-1, Class A-1, Class A-2, Class A-3, Class
A-4, Class A-5, Class A-6, Class A-7, Class A-PO, Class M, Class B-1 and Class
B-2 Certificates (the "Certificates") pursuant to the Pooling and Servicing
Agreement (the "Pooling Agreement"), dated as of January 1, 2000, between the
Company and The Bank of New York (the "Trustee").

                  The Company's Registration Statement on Form S-3 (File No.
333-72459) was filed with the Securities and Exchange Commission (the
"Commission") on February 16, 1999 and was declared effective on May 7, 1999
(the "Registration Statement"). The Certificates have been offered pursuant to
the Core Prospectus dated January 24, 2000 (the "Core Prospectus") and the
Prospectus Supplement relating to the Certificates dated January 24, 2000 (the
"Prospectus Supplement" and, together with the Core Prospectus, the
"Prospectus").

                  In rendering the opinion set forth below, we have examined and
relied upon the following: (i) the Registration Statement and the Prospectus,
(ii) the Pooling Agreement and (iii) such other documents, records and
instruments as we have deemed necessary for the purposes of this opinion.

                  As counsel to the Company, we have advised the Company with
respect to certain federal income tax aspects of the proposed issuance of the
Certificates. Such advice has formed the basis for the description of material
federal income tax consequences for holders of the Certificates that appears
under the heading "Taxation of Certificate holders" and "Taxation of the Trust"
in the Core Prospectus and "Federal Income Tax Consequences" in the Prospectus
Supplement. Such descriptions do not purport to discuss all possible federal
income tax ramifications of the proposed issuance of the Certificates, but, with
respect to those federal income tax consequences that are discussed, in our
opinion, the descriptions are accurate in all material respects.

                  We are furnishing this opinion letter to you solely for your
benefit in connection with the transactions referred to herein. This opinion
letter is not to be relied upon, used, circulated, quoted or otherwise referred
to by any other person or entity or for any other purpose without our prior
written consent. In addition, we disclaim any obligation to update this opinion
for changes in fact or law, or otherwise.

                  We hereby consent to the filing of this letter and to the
reference to this firm under the heading "Legal Opinions" in the Prospectus.
This consent is not to be construed as an admission that we are a person whose
consent is required to be filed with the Prospectus under the provisions of the
Securities Act of 1934, as amended.

                                            Very truly yours,

                                            /s/ Cadwalader, Wickersham & Taft