Subject: File No. 4-606
From: Bradford J von Grote
Affiliation: INdex Funds Advisors

July 30, 2010

Fiduciary should refer to "fee only" advisors. If someone has any conflict of interest such as making commissions either for themselves or the companies they work for from the products they sell to a client - they are not fiduciaries. The fact that they are not fiduciaries should be plastered all over their sales material and contracts.