Exhibit 5.1

[The PNC Financial Services Group, Inc. Letterhead]

December 19, 2012

The PNC Financial Services Group, Inc.

PNC Funding Corp

One PNC Plaza

249 Fifth Avenue

Pittsburgh, PA 15222-2707

Ladies and Gentlemen:

This opinion is issued in connection with the Registration Statement on Form S-3 (the “Registration Statement”) of The PNC Financial Services Group, Inc. (the “Corporation”) and PNC Funding Corp (“PNC Funding”) to be filed with the Securities and Exchange Commission (the “Commission”), relating to the registration under the Securities Act of 1933, as amended (the “Securities Act”), of (i) unsecured debt securities of the Corporation (“Corporation Debt Securities”), (ii) unsecured debt securities of PNC Funding (“PNC Funding Debt Securities” and together with the Corporation Debt Securities, the “Debt Securities”), guaranteed by the Corporation (the “Guarantees”); (iii) warrants of the Corporation to purchase Corporation Debt Securities (“Corporation Debt Warrants”), (iv) warrants of PNC Funding to purchase PNC Funding Debt Securities (“PNC Funding Debt Warrants”); (v) shares of the Corporation’s common stock, par value $5.00 per share (“Common Stock”); (vi) shares of the Corporation’s preferred stock, par value $1.00 per share (“Preferred Stock”); (vii) depositary shares representing Preferred Stock (“Depositary Shares”) to be evidenced by depositary receipts to be issued pursuant to a Deposit Agreement in the event the Corporation elects to offer fractional interests in shares of Preferred Stock; (viii) purchase contracts for the purchase or sale of Common Stock, Preferred Stock, Depositary Shares, Corporation Debt Securities, PNC Funding Debt Securities or securities of a third party (“Purchase Contracts”); (ix) units comprising a combination of any other securities registered under the Registration Statement (“Units”); and (x) warrants of the Corporation to purchase Common Stock, Preferred Stock and Depositary Shares (“Equity Warrants” and together with the Corporation Debt Warrants and the PNC Funding Debt Warrants, the “Warrants”) with an unspecified proposed maximum offering price (as permitted under the Securities Act) for such Corporation Debt Securities, PNC Funding Debt Securities and related Guarantees, Common Stock, Preferred Stock, Depositary Shares, Purchase Contracts, Units, and Warrants (collectively “Securities”), plus an indeterminate number of shares of Common Stock, Preferred Stock and Depositary Shares and an indeterminate principal amount of Debt Securities, in each case issuable upon conversion, exchange or exercise of the Preferred Stock, Debt Securities, Warrants or Purchase Contracts registered thereunder. The Prospectus contained in the Registration Statement is referred to as the “Base Prospectus.” The term “Prospectus” refers to the Base Prospectus and the applicable term sheet, free writing prospectus, prospectus supplement and/or Securities Exchange Act reports referenced in a prospectus supplement with respect to a particular offering of such Securities.

The Corporation Debt Securities will be issued, in the case of senior indebtedness, under the Indenture dated as of September 6, 2012 filed as Exhibit 4.19 of the Registration Statement on Form S-3 filed September 6, 2012 (Registration Nos. 333-164364 and 333-164364-01) and, in the case of subordinated indebtedness, the Indenture dated as of December 19, 2012, filed as Exhibit 4.25 of the Registration Statement (each a “Corporation Indenture”). PNC Funding Debt Securities and the related Guarantees

will be issued under the Indenture dated as of December 1, 1991, as amended and supplemented by the Supplemental Indenture dated as of February 15, 1993 filed as Exhibits 4.7 and Exhibit 4.8, respectively, of the Registration Statement on Form S-3 filed August 29, 1997 (Registration No. 333-34709), as further amended and supplemented by a Second Supplemental Indenture dated February 15, 2000 filed as Exhibit 4.8 of the Registration Statement on Form S-3 filed June 30, 2005 (Registration No. 333-126294), as further amended by a Third Supplemental Indenture dated as of December 19, 2008 and a Fourth Supplemental Indenture dated as of December 19, 2008 (filed as Exhibits 4.1 and 4.2, respectively, of the Form 8-K filed on December 23, 2008) and as further amended by a Fifth Supplemental Indenture dated as of March 31, 2009 filed as Exhibit 4.1 of the Form 8-K filed on April 3, 2009 and, in the case of convertible indebtedness, the Indenture dated as of June 30, 2005 filed as Exhibit 4.11 of the Registration Statement on Form S-3 filed June 30, 2005 (Registration No. 333-126294) (each a “PNC Funding Indenture” and together with the Corporation Indentures, the “Indentures”). Each series of Preferred Stock is to be issued under the Amended and Restated Articles of Incorporation of the Corporation and a statement with respect to shares (a “Statement with Respect to Shares”) to be approved by the Board of Directors of the Corporation or a committee thereof and filed with the Department of State of the Commonwealth of Pennsylvania. The Depositary Shares are to be issued under deposit agreements (the “Deposit Agreements”), to be entered into by the Corporation, a depositary to be named by the Corporation and the holders from time to time of depositary receipts evidencing Depositary Shares. The Warrants are to be issued under warrant agreements (the “Warrant Agreements”), to be entered into by the Corporation or PNC Funding, as the case may be, and warrant agents to be named by the Corporation or PNC Funding, as the case may be. The Purchase Contracts are to be issued under purchase contract agreements (the “Purchase Contract Agreements”) to be entered into by the Corporation or PNC Funding, as the case may be, and the Units are to be issued under unit agreements, indentures or other agreements to be entered into by the Corporation or PNC Funding, as the case may be, and a unit agent or agents to be named by the Corporation or PNC Funding, as the case may be (the “Unit Agreements”). The Common Stock is to be issued under the Amended and Restated Articles of Incorporation of the Corporation. The Indentures, the Deposit Agreements, the Warrant Agreements, the Purchase Contract Agreements and the Unit Agreements are sometimes referred to herein collectively as the “Agreements.”

As Senior Counsel to the Corporation, I have examined (1) the Amended and Restated Articles of Incorporation and By-Laws, each as amended to date, of the Corporation; (2) the Articles of Incorporation and By-Laws, each as amended to date, of PNC Funding; (3) the Indentures, (4) the Registration Statement, including the Base Prospectus and the Exhibits being filed with it and as of this date incorporated therein by reference; (5) the resolutions adopted by the Corporation’s Board of Directors at a meeting duly held on November 15, 2012 and (6) the Unanimous Written Consent of the Board of Directors of PNC Funding dated as of December 7, 2012. I have also examined such records, certificates and other documents relating to the Corporation and PNC Funding that I have considered necessary or appropriate for the purposes of this opinion.

In making such examination and rendering the opinions set forth below, I have assumed: (i) the genuineness and authenticity of all signatures on original documents; (ii) the authenticity of all documents submitted to me as originals; and (iii) the conformity to the originals of all documents submitted to me as certified, telecopied, or reproduced copies and the authenticity of all originals of such documents.

Certain terms of the Securities to be issued by the Corporation or PNC Funding from time to time will be approved by the Board of Directors or a committee thereof or certain authorized officers of the Corporation or PNC Funding as part of the corporate action taken and to be taken (the “Corporate Proceedings”) in connection with issuance of the Securities.

Based upon the foregoing, and subject to the qualifications and limitations stated herein, I am of the opinion that:

The foregoing opinions as to the legality, validity, binding effect and enforceability of provisions of such instruments and agreements are subject to applicable bankruptcy, reorganization, insolvency, moratorium, fraudulent conveyance, receivership or other laws affecting creditors’ rights generally from time to time in effect and subject to general equity principles, including without limitation, concepts of materiality, reasonableness, good faith, fair dealing and the possible unavailability of specific performance, injunctive relief or other equitable remedies (regardless of whether enforceability is considered in a proceeding in equity or at law) and except further as enforcement thereof may be limited by any governmental authority that limits, delays or prohibits the making of payments outside of the United States. As contemplated by the foregoing qualifications, in rendering the foregoing opinions, we are expressing no opinion as to Federal or state laws relating to fraudulent transfers.

The foregoing opinions assume that (a) with respect to any Common Stock held as treasury shares that may be sold, such shares has been validly issued before they were reacquired by the Corporation and became treasury shares, (b) the Corporation and/or PNC Funding, as applicable, will remain duly organized, validly existing and in good standing under the laws of the Commonwealth of Pennsylvania; (c) the consideration designated in the applicable Corporate Proceedings for any Securities shall have been received by the Corporation or PNC Funding, as applicable; (d) the execution of any Deposit Agreement, Warrant Agreement, Purchase Contract Agreement, Unit Agreement, Statement with Respect to Shares and Securities will be by an officer or officers of the Corporation or PNC Funding, as applicable, authorized by the Corporate Proceedings; (e) the Indentures have been, and any Deposit Agreement, Warrant Agreement, Purchase Contract Agreement and Unit Agreement shall have been, duly authorized, executed, and delivered by all parties thereto other than the Corporation or PNC Funding, as applicable, and each such party shall have complied with all legal requirements pertaining to its status as such status relates to its rights to enforce such agreements or instruments against the Corporation or PNC Funding, as applicable, and shall have satisfied those legal requirements applicable to it to the extent necessary to make such agreements or instruments enforceable against it; (f) the Registration Statement shall have become effective under the Securities Act and will continue to be effective; (g) the Indentures shall have been qualified under the Trust Indenture Act of 1939, as amended; and (h) that, at the time of the authentication and delivery of the Securities, the Corporate Proceedings related thereto will not have been modified or rescinded, there will not have occurred any change in the law or in the Articles of Incorporation or By-laws of the Corporation and/or PNC Funding, as applicable, affecting the authorization, execution, delivery, validity or enforceability of such Securities or the Agreements, none of the particular terms of such Securities or Agreements will violate any applicable law or the Articles of Incorporation or By-laws of the Corporation and/or PNC Funding, as applicable and neither the issuance and sale of such Securities nor the compliance by the Corporation with the terms of such Securities or the Agreements will result in a violation of any issuance limit in the Corporate Proceedings, any agreement or instrument then binding upon the Corporation or any order of any court or governmental body having jurisdiction over the Corporation.

In making such examination and rendering the opinions set forth below, I have assumed: (i) the genuineness and authenticity of all signatures on original documents; (ii) the authenticity of all documents submitted to me as originals; and (iii) the conformity to the originals of all documents submitted to me as certified, telecopied, or reproduced copies and the authenticity of all originals of such documents.

I am admitted to practice law in the Commonwealth of Pennsylvania and do not purport to be an expert on or to express any opinion on any laws other than laws of the Commonwealth of Pennsylvania and the federal securities laws of the United States of America. This opinion speaks as of today’s date and is limited to statutes, regulations and judicial interpretations in force as of today’s date. In rendering this opinion, I assume no obligation to revise or supplement this opinion should the foregoing be changed by legislative or regulatory action, judicial decision or otherwise or should the agreements or other documents (or forms thereof) that I have examined in connection with this opinion hereafter be changed.

I hereby consent to the filing of this opinion as an exhibit to the Registration Statement and to the reference to me under the caption “Legal Opinions” in the Prospectus included in Part I of the Registration Statement. In giving such consent, I do not thereby admit that I come within the category of persons whose consent is required under Section 7 of the Securities Act or the rules and regulations of the Commission thereunder.

Very truly yours,

/s/ Christi Davis

Christi Davis

Senior Counsel