June 25, 1998

Bank of South Windsor
I695 Ellington Road
South Windsor, CT 06074-4514

Ladies and Gentlemen:

         You have requested our opinion as to certain federal income tax
consequences to Bank of South Windsor, a Connecticut-chartered commercial bank
CBSW"), New England Community Bancorp, Inc., a Delaware corporation CNECB"), and
the shareholders of BSW, resulting from the consummation of the merger (the
"Merger") of BSW, with. and into New England Bank & Trust Company, a
Connecticut-chartered commercial bank and wholly-owned subsidiary of NECB (the
"Bank") pursuant to the Agreement and Plan of Merger dated as of March 19, 1998,
(the "Merger Agreement"), among BSW, NECB and the Bank.

         Except as otherwise provided, capitalized terms not defined herein have
the meanings set forth in the Merger Agreement. All section references, unless
otherwise indicated, are to the Internal Revenue Code of 1986, as amended (the
"Code").

         Pursuant to the Merger Agreement, (i) BSW wi11 be merged with and into
the Bank, (ii) all shares of BSW common stock issued and outstanding immediately
prior to the Effective Time shall be converted into the right to receive shares
of Class A common stock, par value $.10 per share, of NECB, (iii) each share of
BSW common stock (hereinafter referred to as "BSW Common Stock") issued and
outstanding immediately prior to the Effective Time (other than any shares of
BSW Common Stock (a) which are Dissenting Shares, or (b) which are shares held
by NECB or the Bank other than in a fiduciary or trust capacity for the benefit
of third parties) will be converted into the right to receive 1.3204 shares of
NECB common stock (hereinafter referred to as "NECB common stock") and (iv) the
shareholders of BSW will receive cash in lieu of fractional interests in the
NECB common stock to which they would otherwise be entitled.
<PAGE>


         Such description of the transaction set forth above, and our opinion as
stated herein, are based upon and subject to (i) the Merger and related
transactions being effected in the manner described in the draft Form of Joint
Proxy Statement Prospectus forming a part of NECB's Registration Statement on
Form S-4 dated May 29, 1998 (the "Proxy Statement / Prospectus") and in
accordance with the provisions of the Merger Agreement, (ii) the accuracy of the
representations made to us by NECB and the Bank and BSW in their respective
officer's certificates each dated June 23, 1998 and delivered to its for
purposes of this opinion (the "Officer's Certificates"), which representations
shall, by the terms of such Officer's Certificates, be true and correct at all
times through the Effective Time of the Merger, (iii) the accuracy of the
representations and compliance with the covenants contained in the Merger
Agreement made by the respective parties thereto, insofar as they relate to or
affect the tax treatment of the transactions contemplated in the Merger
Agreement, which representations and/or covenants shall be satisfied and/or true
and correct, as the case may be, at all times through and/or after the Effective
Time of the Merger, (v) the accuracy of the statements set forth in the Proxy
Statement / Prospectus as to the purposes of the parties for consummating the
Merger, and (v) none of the compensation to be received by any holder of BSW
Common Stock who is an employee of BSW pursuant to any employment agreement or
any covenants not to compete or other arrangement will be separate consideration
for any of such holder's shares of BSW Common Stock.

         In rendering our opinion, we have considered the applicable provisions
of the Code, Treasury Regulations, pertinent judicial authorities, interpretive
rulings of the Internal Revenue Service and such other authorities as we have
considered relevant as of the date of this opinion, and any subsequent change
therein may adversely affect the conclusions reached in this opinion and such
opinion may not then be relied upon.

         Based on our examination of the foregoing items and subject to the
limitations set forth herein, we are of the opinion that for federal income tax
purposes:

         1. The Merger of BSW with and into Bank, with Bank surviving, will
qualify as a reorganization under Section 368(a) of the Code. BSW, NECB and Bank
will each be a party to the reorganization within the meaning of Section 368(b)
of the Code. 
<PAGE>

         2. No gain or loss will be recognized by a shareholder of BSW upon the
exchange of their BSW Common Stock for the right to receive NECB common stock
and the exercise of such right by a shareholder of BSW.

         3. The aggregate tax basis of the NECB Common Stock received by a
shareholder of BSW in the exchange (including any fractional shares which the
BSW shareholder otherwise might be entitled to receive) will be the same as the
basis of the BSW Common Stock exchanged therefor.

         4. Cash received by a shareholder of BSW in lieu of a fractional share
of NECB Common Stock or for Dissenting Shares will be treated as if the
fractional shares or Dissenting Shares were received in exchange of such
fractional shares or Dissenting Shares pursuant to Section 302(a) of the Code as
a redemption, and not as a dividend under Section 301 of the Code. Any gain or
loss recognized as a result of the receipt of such cash will be capital gain or
loss under Section 1222 of the Code, if such stock was held as a capital asset
at the time of the exchange, equal to the difference between the cash received
and the shareholder's basis in the NECB Common Stock for which such fractional
share interest or Dissenting Shares is received.

         This opinion is rendered solely with respect to certain United States
federal income tax consequences of the Merger under the Code as specifically set
forth herein, and does not extend to the income or other potential tax
consequences of the Merger under the laws of any State or any political
subdivision of any State or any other jurisdiction nor does it extend to any tax
effects or consequences of the Merger to NECB, the Bank or BSW other than those
expressly stated in this opinion. Furthermore, no opinion is expressed as to the
United States federal or state tax treatment of the transaction under any other
provisions of the Code and regulations, or about the tax treatment of any
conditions existing at the time of, or effects resulting From, the transaction
that is not specifically covered by this opinion. In addition, this opinion may
not be relied upon except with respect to the consequences specifically
discussed herein. This opinion is being furnished only to BSW and the
shareholders of BSW in connection with the Merger in accordance with the Merger
Agreement and solely for their benefit in connection therewith and may not be
used or relied upon for any other purpose and may not be circulated, quoted or
otherwise referred to for any other purpose without our prior express written
consent except that

<PAGE>

this opinion may be included as an exhibit in the Proxy Statement - Prospectus.
Additionally, we hereby consent to the reference to our Firm in the Proxy
Statement - Prospectus.



                                             Very truly yours,

                                             /s/Cummings & Lockwood
                                             ----------------------
                                             Cummings & Lockwood