EXHIBIT 5.1 June 29, 2006Wells Fargo Asset Securities Corporation7430 New Technology WayFrederick, Maryland 21703 Re: Wells Fargo Asset Securities Corporation Series 2006-AR10Ladies and Gentlemen: We have acted as special counsel to Wells Fargo Asset SecuritiesCorporation (the “Company”) in connection with the proposed sale by the Companyand purchase by Deutsche Bank Securities Inc., as underwriter (the”Underwriter”), of Wells Fargo Mortgage Backed Securities 2006-AR10 Trust,Mortgage Pass-Through Certificates, Series 2006-AR10, Class I-A-1, Class I-A-2,Class I-A-R, Class II-A-1, Class II-A-2, Class III-A-1, Class III-A-2, ClassIV-A-1, Class IV-A-2, Class V-A-1, Class V-A-2, Class V-A-3, Class V-A-4, ClassV-A-5, Class V-A-6, Class V-A-7, Class B-1, Class B-2 and Class B-3(collectively the “Certificates”), pursuant to the terms of the underwritingagreement, dated February 15, 2006, and terms agreement, dated June 5, 2006(collectively, the “Underwriting Agreement”), among the Company, Wells FargoBank, N.A. (“Wells Fargo Bank”) and the Underwriter. The Certificates are beingissued pursuant to a Pooling and Servicing Agreement, dated June 29, 2006 (the”Pooling and Servicing Agreement”), among the Company, Wells Fargo Bank, asmaster servicer (the “Master Servicer”), and HSBC Bank USA, NationalAssociation, as trustee (the “Trustee”). Capitalized terms used herein but notdefined herein have the respective meanings given them in the Pooling andServicing Agreement. In rendering the opinions set forth below, we have examined andrelied upon the originals, copies or specimens, certified or otherwiseidentified to our satisfaction, of the Transaction Documents (as defined below)and such certificates, corporate and public records, agreements and instrumentsand other documents, including, among other things, the documents delivered onthe date hereof, as we have deemed appropriate as a basis for the opinionsexpressed below. In such examination we have assumed the genuineness of allsignatures, the authenticity of all documents, agreements and instrumentssubmitted to us as originals, the conformity to original documents, agreementsand instruments of all documents, agreements and instruments submitted to us ascopies or specimens, the authenticity of the originals of such documents,agreements and instruments submitted to us as copies or specimens, theconformity of the text of each document filed with the Securities and ExchangeCommission (the “Commission”) through the Commission’s Electronic DataGathering, Analysis and Retrieval System to the printed document reviewed by us,and the accuracy of the matters set forth in the documents, agreements andinstruments we reviewed. As to matters of fact relevant to the opinionsexpressed herein, we have relied upon, and assumed the accuracy of, therepresentations and warranties contained in the Underwriting Agreement and thePooling and Servicing Agreement and we have relied upon certificates and oral orwritten statements and other information obtained from the Company, the otherparties to the transaction referenced herein, and public officials. Except asexpressly set forth herein, we have not undertaken any independent investigation(including, without limitation, conducting any review, search or investigationof any public files, records or dockets) to determine the existence or absenceof the facts that are material to our opinions, and no inference as to ourknowledge concerning such facts should be drawn from our reliance on therepresentations of the Company in connection with the preparation and deliveryof this letter. In particular, we have examined and relied upon: (i) the Prospectus,dated June 27, 2006 (the “Prospectus”) and the Prospectus Supplement, dated June27, 2006 (the “Prospectus Supplement”), relating to the offering of theCertificates and (ii) the Pooling and Servicing Agreement. Items (i) and (ii) above are referred to in this letter as the”Transaction Documents.” We have also assumed that all documents, agreements and instrumentshave been duly authorized, executed and delivered by all parties thereto, thatall such parties are validly existing and in good standing under the laws oftheir respective jurisdictions of organization, that all such parties had thepower and legal right to execute and deliver all such documents, agreements andinstruments, and (other than with respect to the Company) that such documents,agreements and instruments are legal, valid and binding obligations of suchparties, enforceable against such parties in accordance with their respectiveterms. As used herein, “to our knowledge,” “known to us” or words of similarimport mean the actual knowledge, without independent investigation, of anylawyer in our firm actively involved in the transactions contemplated by theUnderwriting Agreement. We express no opinion concerning the laws of any jurisdiction otherthan the laws of the State of New York and, to the extent expressly referred toin this letter, the federal laws of the United States of America. Based upon and subject to the foregoing, we are of the opinion that: 1. The Certificates have been duly authorized by the Company, and when the Certificates have been duly executed by the Paying Agent and countersigned by the Authenticating Agent and paid for and sold to the Underwriter as contemplated in the Prospectus and Prospectus Supplement, the Certificates will be legally issued, fully paid and non-assessable; and 2. The descriptions of federal income tax consequences appearing under the headings “Certain Federal Income Tax Consequences” in the Prospectus and “Federal Income Tax Considerations” in the Prospectus Supplement accurately describe the material federal income tax consequences to holders of the Certificates, under existing law and subject to the qualifications and assumptions stated therein. We also hereby confirm and adopt the opinions expressly set forth under such headings, under existing law and subject to the qualifications and assumptions stated therein. We hereby consent to the filing of this letter as an exhibit to theCompany’s Registration Statement on Form S-3 (File No. 333-129159) (the”Registration Statement”) filed on October 20, 2005 and declared effective onFebruary 2, 2006, as it relates to the Certificates and to the reference to thisfirm under the headings “Legal Matters” and “Certain Federal Income TaxConsequences” in the Prospectus and “Legal Matters” and “Federal Income TaxConsiderations” in the Prospectus Supplement. This consent is not to beconstrued as an admission that we are a person whose consent is required to befiled with the Registration Statement under the provisions of the Securities Actof 1933, as amended. No opinion has been sought and none has been given concerning thetax treatment of the issuance and sale of the Certificates under the laws of anystate. In addition, we disclaim any obligation to update this letter for changesin fact or law, or otherwise. Very truly yours, /s/ Cadwalader, Wickersham & Taft LLP