{"url_path":"/sec/cik-0002136440/8-k/2026-06-29/body","section_key":"body","section_title":"Body","topic":"sec","document":{"doc_type":"8-K","doc_date":"2026-06-29","source_url":"https://www.sec.gov/Archives/edgar/data/2136440/0001539497-26-001882-index.html","accession_number":"0001539497-26-001882","cik":"0002136440","ticker":null,"issuer_name":"Wells Fargo Commercial Mortgage Trust 2026-5C10","edgar_url":"https://www.sec.gov/Archives/edgar/data/2136440/0001539497-26-001882-index.html","primary_entity_key":"0002136440","primary_entity_name":"Wells Fargo Commercial Mortgage Trust 2026-5C10"},"word_count":1217,"has_tables":true,"body_markdown":"EX-5\n2\nn5926_exh5.htm\nLEGALITY OPINION OF CADWALADER, WICKERSHAM & TAFT LLP, DATED JUNE 29, 2026.\n\n**Exhibit\n5**\n\n**C A D W A L A D E R**\n\nCadwalader,\nWickersham & Taft LLP\n\n650\nSouth Tryon Street, Charlotte, NC 28202\n\nTel\n+1 704 348 5100 Fax +1 704 348 5200\n\nwww.cadwalader.com\n\nJune 29, 2026\n\nWells Fargo Commercial Mortgage Securities, Inc.\n\nc/o Wells Fargo Securities, LLC\n\n30 Hudson Yards, 15th Floor\n\nNew York, New York 10001\n\nRe:Wells Fargo Commercial Mortgage Trust 2026-5C10,\n\nCommercial Mortgage Pass-Through Certificates, Series 2026-5C10\n\nTo the Addressees of this Letter:\n\nWe have acted as special\ncounsel to Wells Fargo Commercial Mortgage Securities, Inc. (the “Company”) in connection with the proposed sale by\nthe Company and purchase by Wells Fargo Securities, LLC (“WFS”), SG Americas Securities, LLC (“SGAS”),\nCitigroup Global Markets Inc. (“CGMI”), Goldman Sachs & Co. LLC (“GS&Co.”), J.P. Morgan\nSecurities LLC (“JPMS”), UBS Securities LLC (“UBS Securities”), Academy Securities, Inc. (“Academy”),\nDrexel Hamilton, LLC (“Drexel”) and Siebert Williams Shank & Co., LLC (“Siebert Williams” and\ntogether with WFS, SGAS, CGMI, GS&Co., JPMS, UBS Securities, Academy and Drexel, the “Underwriters”) of the Wells\nFargo Commercial Mortgage Trust 2026-5C10, Commercial Mortgage Pass-Through Certificates, Series 2026-5C10, Class A-1, Class A-3,\nClass X-A, Class X-B, Class A-S, Class B and Class C (the “Offered Certificates”), pursuant to the terms of the Underwriting\nAgreement, dated as of June 18, 2026 (the “Agreement”), between the Company, Wells Fargo Bank, National Association,\nWFS, SGAS, CGMI, GS&Co. JPMS, Academy, Drexel and Siebert Williams. The Offered Certificates are being issued pursuant to a Pooling\nand Servicing Agreement, dated as of June 1, 2026 (the “Pooling and Servicing Agreement”), among the Company, Trimont\nLLC, as master servicer, Argentic Services Company LP, as special servicer, Computershare Trust Company, National Association, as certificate\nadministrator (the “Certificate Administrator”), Deutsche Bank National Trust Company, as trustee, and Park Bridge\nLender Services LLC, as operating advisor and asset representations reviewer. This letter is being delivered at the request of the Company\npursuant to the Agreement. Capitalized terms used herein but not defined herein have the respective meanings given them in the Agreement.\n\nIn rendering the opinions\nset forth below, we have examined and relied upon the originals, copies or specimens, certified or otherwise identified to our satisfaction,\nof the Agreement and the Pooling and Servicing Agreement and such certificates, corporate and public records, agreements and instruments\nand other documents, including, among other things, the documents delivered on the date hereof, as we have deemed appropriate as a basis\nfor the opinions expressed below. In such examination we have assumed the genuineness of all\n\nsignatures, the authenticity of all documents,\nagreements and instruments submitted to us as originals, the conformity to original documents, agreements and instruments of all documents,\nagreements and instruments submitted to us as copies or specimens, the authenticity of the originals of such documents, agreements and\ninstruments submitted to us as copies or specimens, the conformity of the text of each document filed with the Securities and Exchange\nCommission (the “Commission”) through the Commission’s Electronic Data Gathering, Analysis and Retrieval System\nto the printed document reviewed by us, the accuracy of the matters set forth in the documents, agreements and instruments we reviewed,\nand that such documents, agreements and instruments evidence the entire understanding between the parties thereto and have not been amended,\nmodified or supplemented in any manner material to the opinions expressed herein. As to matters of fact relevant to the opinions expressed\nherein, we have relied upon, and assumed the accuracy of, the representations and warranties contained in the Agreement and the Pooling\nand Servicing Agreement and we have relied upon certificates and oral or written statements and other information obtained from the Company,\nthe other parties to the transaction referenced herein, and public officials. Except as expressly set forth herein, we have not undertaken\nany independent investigation (including, without limitation, conducting any review, search or investigation of any public files, records\nor dockets) to determine the existence or absence of the facts that are material to our opinions, and no inference as to our knowledge\nconcerning such facts should be drawn from our reliance on the representations of the Company and others in connection with the preparation\nand delivery of this letter.\n\nWe have also assumed (x)\nthe legal capacity of all natural persons and (y) (except to the extent expressly opined on herein) that all documents, agreements and\ninstruments have been duly authorized, executed and delivered by all parties thereto, that all such parties are validly existing and in\ngood standing under the laws of their respective jurisdictions of organization, that all such parties had the power and legal right to\nexecute and deliver all such documents, agreements and instruments, and that such documents, agreements and instruments constitute the\nlegal, valid and binding obligations of such parties, enforceable against such parties in accordance with their respective terms. As used\nherein, “to our knowledge”, “known to us” or words of similar import mean the actual knowledge, without independent\ninvestigation, of any lawyer in our firm actively involved in representing the Company with respect to the transactions contemplated by\nthe Agreement.\n\nWe express no opinion concerning\nthe laws of any jurisdiction other than the laws of the State of New York and, to the extent expressly referred to in this letter, the\nfederal laws of the United States of America.\n\nBased upon and subject to\nthe foregoing, we are of the opinion that:\n\n1.                 \nWhen the Offered Certificates have been duly executed, authenticated and delivered by the Certificate Administrator in the manner\ncontemplated in the Pooling and Servicing Agreement and paid for by and sold to the Underwriters pursuant to the Agreement, the Offered\nCertificates will be validly issued and outstanding, fully paid and non-assessable and entitled to the benefits provided by the Pooling\nand Servicing Agreement.\n\n-2-\n\n2.                 \nThe descriptions of federal income tax consequences appearing under the heading “Material Federal Income Tax Considerations”\nin the Company’s Prospectus, dated June 22, 2026 (the “Prospectus”), accurately describe the material federal\nincome tax consequences to holders of the Offered Certificates, under existing law and subject to the qualifications and assumptions stated\ntherein. We also hereby confirm and adopt the opinions expressly set forth under such headings, under existing law and subject to the\nqualifications and assumptions stated therein.\n\nWe hereby consent to the\nfiling of this letter as an exhibit to the Company’s Registration Statement on Form SF-3 (File No. 333-282099) filed with the\nCommission on September 13, 2024, as amended by a Form SF-3/A filed on October 30, 2024, as declared effective on December 2,\n2024 (excluding any exhibits thereto, the “Registration Statement”), as it relates to the Offered Certificates, and\nto the reference to Cadwalader, Wickersham & Taft LLP and the discussion of our opinions set forth in this letter under the headings\n“Material Federal Income Tax Considerations” and “Legal Matters” in the Prospectus. This consent is not to be\nconstrued as an admission that we are a person whose consent is required to be filed with the Registration Statement under the provisions\nof the Securities Act of 1933, as amended.\n\nIn addition, we disclaim\nany obligation to update this letter or communicate with or advise you as to any changes in fact or law, or otherwise.\n\nVery truly yours,\n\n/s/ Cadwalader, Wickersham & Taft LLP\n\n-3-"}