EXHIBIT 23(i)
Opinion of Counsel
<PAGE>
June 12, 2000
IDEX Mutual Funds
570 Carillon Parkway
St. Petersburg, Florida 33716
Re: IDEX Mutual Funds
Offering of Shares of Beneficial Interest
Gentlemen:
In my capacity as Vice President, Secretary and Counsel, I have acted
as counsel for IDEX Mutual Funds (the "Fund") and have reviewed the Registration
Statement under the Securities Act of 1933 on Form N-1A, and amendments thereto,
with respect to the offer and sale of shares of beneficial interest , no par
value, of the above-referenced Fund, including the "Rule 24f-2 Notice" for the
period ended October 31, 1999, registering such shares pursuant to such
Registration Statement, as amended, in accordance with Rule 24f-2 under the
Investment Company Act of 1940.
I have examined the Fund's Declaration of Trust and Bylaws, as
amended, the proceedings of its Board of Trustees relating to the authorization,
issuance, and proposed sales of the shares, and such other records and documents
as I deemed relevant. Based upon such examination, it is my opinion that upon
the issuance and sale of the shares of beneficial interest of the Fund in the
manner contemplated by the aforesaid Registration Statement, as amended, such
shares were validly issued, fully paid and nonassessable outstanding shares of
benficial interest of the Fund.
Very truly yours,
/s/John K. Carter
John K. Carter
Vice President, Secretary
and Counsel
