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S-1/A - AMENDMENT NO. 3 TO FORM S-1 - HUI YING FINANCIAL HOLDINGS Corpg7828.txt
EX-23.2 - CONSENT OF AUDITOR - HUI YING FINANCIAL HOLDINGS Corpex23-2.txt

                                                                     Exhibit 5.1

SCOTT D. OLSON ESQ.                                                 274 BROADWAY
                                                            COSTA MESA, CA 92627
ATTORNEY AT LAW                                                 TEL 310.985.1034
                                                                FAX 310.564.1912
                                                          EMAIL SDOESQ@GMAIL.COM
                                                           SKYPE SCOTTDAVIDOLSON


April 20 , 2015

Tapioca Corp.
Lasi, Vasile Lupu nr. 83, bl. D1, sc. B, Suite 37
Romania
tapiocagroupcorp@gmail.com

     Re: Registration Statement on Form S-1

Ladies and Gentlemen:

I have  acted  as  special  counsel  to  Tapioca  Corp.,  a  Nevada  corporation
("Company") for the limited purpose of rendering this opinion in connection with
the  proposed  issuance  and sale of up to  10,000,000  shares of the  Company's
common stock,  par value $0.001 per share  ("Shares")  pursuant to the Company's
Registration   Statement  on  Form  S-1  and  the  prospectus  included  therein
(collectively  the  "Registration  Statement")  filed  with the  Securities  and
Exchange  Commission  ("SEC") under the  Securities Act of 1933, as amended (the
"Act").

In  connection  with  this  opinion,   I  have  examined  and  relied  upon  the
Registration Statement, the Company's Articles of Incorporation, its Bylaws, and
the originals or copies certified to my satisfaction of such records, documents,
certificates, memoranda and other instruments as in my judgment are necessary or
appropriate to enable me to render the opinion  expressed  below. I have assumed
the genuineness and authenticity of all documents  submitted to me as originals,
the  conformity to originals of all documents  submitted to me as copies thereof
and the due  execution  and delivery of all  documents  where due  execution and
delivery are a prerequisite to the effectiveness thereof.

On the basis of the foregoing, and in reliance thereon, I am of the opinion that
the Shares will be, when sold, validly issued, fully paid and nonassessable.

This opinion  letter is opining upon and is limited to the current  federal laws
of the United States and the Nevada  Revised  Statutes,  including the statutory
provisions,  all applicable provisions of the Nevada constitution,  and reported
judicial decisions  interpreting those laws, as such laws presently exist and to
the facts as they  presently  exist.  I express no opinion  with  respect to the
effect  or  applicability  of the laws of any  other  jurisdiction.  I assume no
obligation to revise or supplement  this opinion  letter should the laws of such
jurisdiction  be changed after the date hereof by legislative  action,  judicial
decision or otherwise.

I hereby consent to the filing of this opinion with the Commission as an exhibit
to the  Registration  Statement  in  accordance  with the  requirements  of Item
601(b)(5) of Regulation  S-K under the Act and to the use of my name therein and
in the related  prospectus  under the caption  "Legal  Matters."  In giving such
consent,  I do not hereby  admit  that I am in the  category  of  persons  whose
consent is required  under Section 7 of the Act or the rules and  regulations of
the SEC.

                                          Very truly yours,


                                          /s/ Scott D. Olson Esq.
                                          -------------------------------------
                                          Scott D. Olson Esq