February 16, 1999


Citicorp Mortgage Securities, Inc.
909 Third Avenue
New York, New York 10043

Citicorp
399 Park Avenue
New York, New York 10043


                       Re: REMIC Pass-Through Certificates

Gentlemen:

         I am a Vice President of Citibank, N.A., and have acted as your tax
counsel in connection with the proposed issuance of REMIC Pass-Through
Certificates (the "Certificates") pursuant to a Registration Statement on Form
S-3 (the "Registration Statement), which is being filed with the Securities and
Exchange Commission (the "Commission") under the Securities Act of 1933, as
amended (the "Act"). Capitalized terms used and not otherwise defined herein are
intended to have the respective meanings ascribed to such terms in the
Registration Statement.

         In rendering the opinion set forth below, I have examined and relied
upon the following: (1) the Registration Statement and the Prospectus forming a
part thereof (the "Prospectus"), substantially in the form to be filed with the
Commission; (2) the forms of Pooling and Servicing Agreements filed and being
filed as exhibits to the Registration Statement; and (3) such other documents,
materials, and authorities as I have deemed necessary in order to enable me to
render my opinion set forth below.

         As your tax counsel, I have advised you 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 headings "Taxation of
Certificate Holders" and "Taxation of the Trust" in the Prospectus. Such
description does not purport to discuss all possible federal income tax
ramifications of the proposed issuance of the

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Citicorp Mortgage Securities
Citicorp
February 16, 1999
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Certificates, but, with respect to those federal income tax consequences which
are discussed, in my opinion the description is accurate in all material
respects.

         The foregoing opinions are based on the facts and circumstances set
forth in the Prospectus and in the other documents reviewed by me. My opinion as
to the matters set forth herein could change with respect to a particular Series
of Certificates as a result of changes in facts and circumstances, change in the
terms of the documents reviewed by me, or changes in the law subsequent to the
date hereof. As the Registration Statement contemplates Series of Certificates
with numerous different characteristics, the particular characteristics of each
Series of Certificates  must be considered in determining the applicability of
this opinion to a particular Series of Certificates.

         I hereby consent to the filing of this letter as an exhibit to the
Registration Statement and to the reference to this opinion under the heading
"Taxation of the Trust" in the Prospectus, without admitting that I am an
"expert" within the meaning of the Act or the rules or regulations of the
Commission issued thereunder.

                                                     Very truly yours,


                                                     /s/ Rona Daniels
                                                     ----------------
                                                     Rona Daniels