EXHIBIT 11


December 26, 2001




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 Senior 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-14, and amendments thereto,
with respect to the offer and shares of beneficial interest, no par value, of
the above-referenced Fund, including the "Rule 24f-2 Notice" for the period
ended October 31, 2000, 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
beneficial interest of the Fund.

Very truly yours,

/s/ John K. Carter, Esq.
Vice President, Secretary and
Senior Counsel