HYUNDAI ABS FUNDING LLC

EX-5.1 · tm2615711d9_ex5-1.htm

EX-5.1
 2
 tm2615711d9_ex5-1.htm
 EXHIBIT 5.1

 Exhibit 5.1

 Mayer Brown LLP
 71 South Wacker Drive
 Chicago, IL 60606
 United States of America

 T: +1 312 782 0600

F: +1 312 701 7711

mayerbrown.com

 June 11, 2026

 Hyundai ABS Funding, LLC

 3161 Michelson Drive, Suite 1900

 Irvine, California 92612

 Re:
 Hyundai ABS Funding, LLC

 Registration Statement on Form SF-3

 Registration No. 333-284087

 Ladies and Gentlemen:

 We have acted as special counsel
to Hyundai ABS Funding, LLC (the “ Company ”), a Delaware limited liability company, in connection with the above-captioned
registration statement (such registration statement, together with the exhibits and any amendments thereto, the “ Registration
Statement ”) filed by the Company with the Securities and Exchange Commission (the “ Commission ”) under the
Securities Act of 1933, as amended (the “ Act ”), and the offering of the Class A-1 Auto Loan Asset Backed Notes,
the Class A-2-A Auto Loan Asset Backed Notes, the Class A-2-B Auto Loan Asset Backed Notes, the Class A-3 Auto Loan Asset
Backed Notes, the Class A-4 Auto Loan Asset Backed Notes, the Class B Auto Loan Asset Backed Notes and the Class C Auto
Loan Asset Backed Notes (the “ Notes ”) described in the final prospectus dated June 9, 2026 (the “ Prospectus ”),
which has been filed with the Securities and Exchange Commission pursuant to Rule 424(b)(5) under the Securities Act of 1933,
as amended (the “ Act ”). As described in the Prospectus, the Notes will be issued by Hyundai Auto Receivables Trust
2026-B (the “ Trust ”), which was formed by the Company pursuant to a trust agreement between the Company and U.S. Bank
Trust National Association, as owner trustee. The Notes will be issued pursuant to an indenture (the “ Indenture ”) between
the Trust and Citibank, N.A., as indenture trustee (the “ Indenture Trustee ”). Capitalized terms used herein without
definition have the respective meanings assigned to such terms in the Prospectus.

 In that regard, we generally
are familiar with the proceedings taken or required to be taken in connection with the proposed authorization, issuance and sale of the
Notes and have examined and relied upon copies of such statutes, documents, corporate records and other instruments as we have deemed
necessary or appropriate for the purposes of this opinion, including the Prospectus and current drafts of the Indenture (including the
form of the Notes included as an exhibit thereto), the Amended and Restated Trust Agreement (including the form of Certificate included
as an exhibit thereto), the Receivables Purchase Agreement, the Sale and Servicing Agreement, the Asset Representations Review Agreement
and the Owner Trust Administration Agreement (collectively, the “ Operative Documents ”).

 Mayer Brown is a global services provider comprising an association of legal practices that are separate entities including

 Mayer Brown
LLP (Illinois, USA), Mayer Brown International LLP (England & Wales), Mayer Brown Hong Kong LLP (a Hong Kong limited liability

 partnership)
and Tauil & Chequer Advogados (a Brazilian law partnership).

 Mayer Brown llp

Hyundai ABS Funding, LLC

 Page 2

 Based on and subject to the
foregoing, we are of the opinion that, with respect to the Notes, when (a) the Indenture has been duly qualified under the Trust
Indenture Act of 1939, as amended, (b) the Notes have been duly executed and issued by the Trust and authenticated by the Indenture
Trustee and sold by the Company or by the Trust, at the direction of the Company, as applicable, and (c) payment of the agreed consideration
for the Notes shall have been received by the Trust, all in accordance with the terms and conditions of the related Operative Documents
and a definitive purchase, underwriting or similar agreement with respect to the Notes and in the manner described in the Prospectus,
the Notes will have been duly authorized by all necessary action of the Trust and will be legally issued and binding obligations of the
Trust and entitled to the benefits afforded by the Indenture, except as may be limited by bankruptcy, insolvency, reorganization, arrangement,
moratorium or other laws relating to or affecting creditors’ rights generally (including, without limitation, fraudulent conveyance
laws), and by general principles of equity, regardless of whether such matters are considered in a proceeding in equity or at law.

 Our opinions expressed herein
are limited to the federal laws of the United States and the laws of the State of New York and the State of Delaware. We hereby consent
to the filing of this opinion with the Commission as Exhibit 5.1 to a Form 8-K filed in connection with the Prospectus and to
the use of our name therein without admitting we are “experts” within the meaning of the Act, or the rules and regulations
of the Commission issued thereunder, with respect to any part of the Registration Statement or the Prospectus.

 Very
 truly yours,

 /s/
 Mayer Brown LLP

 MAYER
 BROWN LLP

EX-8.1 · tm2615711d9_ex8-1.htm

EX-8.1
 3
 tm2615711d9_ex8-1.htm
 EXHIBIT 8.1

 Exhibit 8.1

 Mayer Brown LLP
 71 South Wacker Drive

Chicago, IL 60606
 United States of America

T: +1 312 782 0600

F: +1 312 701 7711

mayerbrown.com

 June 11, 2026

 Hyundai ABS Funding, LLC

3161 Michelson Drive, Suite 1900

Irvine, California 92612

 Re:
 Hyundai ABS Funding, LLC

 Registration Statement on Form SF-3

 Registration No. 333-284087

 Ladies and Gentlemen:

 We have acted as special federal tax counsel to
Hyundai ABS Funding, LLC (the “ Company ”), a Delaware limited liability company, in connection with the above-captioned
registration statement (such registration statement, together with the exhibits and any amendments thereto, the “ Registration
Statement ”) and the offering of the Class A-1 Auto Loan Asset Backed Notes, the Class A-2-A Auto Loan Asset Backed
Notes, the Class A-2-B Auto Loan Asset Backed Notes, the Class A-3 Auto Loan Asset Backed Notes, the Class A-4 Auto Loan
Asset Backed Notes, the Class B Auto Loan Asset Backed Notes and the Class C Auto Loan Asset Backed Notes (collectively, the “ Notes ”)
described in the final prospectus dated June 9, 2026 (the “ Prospectus ”), which has been filed with the Securities
and Exchange Commission (the “ Commission ”) pursuant to Rule 424(b)(5) under the Securities Act of 1933, as
amended (the “ Act ”). As described in the Prospectus, the Notes will be issued by Hyundai Auto Receivables Trust 2026-B
(the “ Trust ”), which was formed by the Company pursuant to a trust agreement between the Company and U.S. Bank Trust
National Association, as owner trustee. The Notes will be issued pursuant to an indenture between the Trust and Citibank, N.A., as indenture
trustee. Capitalized terms used herein without definition have the respective meanings assigned to such terms in the Prospectus.

 In that regard, we generally are familiar with
the proceedings required to be taken in connection with the proposed authorization, issuance and sale of the Notes and have examined copies
of such documents, corporate records and other instruments as we have deemed necessary or appropriate for the purpose of this opinion,
including the Prospectus, the Trust Agreement, the Indenture and other documents prepared in connection with the issuance of the Notes
(collectively, the “ Operative Documents ”). In addition, we have assumed that the Operative Documents with respect to
the Notes are executed and delivered in substantially the form we have examined and that the transactions contemplated to occur under
the Operative Documents in fact occur in accordance with the terms thereof.

 Mayer Brown is a global services provider comprising
an association of legal practices that are separate entities including

Mayer Brown LLP (Illinois, USA), Mayer Brown International LLP (England & Wales), Mayer Brown Hong Kong LLP (a Hong Kong limited
liability

 partnership) and Tauil & Chequer Advogados (a Brazilian law partnership).

 Mayer Brown llp

 Hyundai ABS Funding, LLC

 Page 2

 We hereby confirm and adopt the Opinions set forth
in the Prospectus (to the extent they relate to federal income tax consequences) under the captions “ Summary of Terms—Tax
Status ” and “ Material United States Federal Income Tax Consequences .”

 The opinion set forth herein is based upon the
applicable provisions of the Internal Revenue Code of 1986, as amended, Treasury regulations promulgated and proposed thereunder, current
positions of the Internal Revenue Service (“ IRS ”) contained in published Revenue Rulings and Revenue Procedures, current
administrative positions of the IRS and existing judicial decisions. No tax rulings will be sought from the IRS with respect to any of
the matters discussed herein. The statutory provisions, regulations and interpretations on which our opinions are based are subject to
change, which changes could apply retroactively. In addition, there can be no assurance that positions contrary to those stated in our
opinion may not be taken by the IRS.

 We know that we are referred to under the captions
referred to above included in the Prospectus, and we hereby consent to the use of our name therein and to the use of this opinion for
filing of this opinion as Exhibit 8.1 to a Form 8-K filed in connection therewith, without admitting we are “experts”
within the meaning of the Act, or the rules and regulations of the Commission issued thereunder, with respect to any part of the
Registration Statement or Prospectus, including this exhibit.

 Sincerely,

 /s/
 Mayer Brown LLP

 MAYER
 BROWN LLP