Subject: File No. 4-606
From: Jay D Franklin, CFA
Affiliation: Risk Manager, Index Funds Advisors

July 29, 2010

It is long overdue that brokers be legally required to put their clients interests first. This means no more high expense funds with hidden fees. Also, no more proprietary structured products that generate high fees for brokers and do nothing for the client beyond what he could have received with a low-cost, risk-appropriate portfolio of index funds.