September 27, 2006


Principal Investors Fund, Inc.
Des Moines, Iowa  50392

RE:      Registration Statement on Form N-14
         Pursuant to Securities Act of 1933
         Registration No. 333-__________

I am familiar with the organization of Principal Investors Fund, Inc. (the
"Fund") under the laws of the State of Maryland and have reviewed the
above-referenced Registration Statement (the "Registration Statement") filed
with the Securities and Exchange Commission relating to the offer and sale of a
number of shares of the Corporation's Common Stock, par value $.01 per share
(the "Shares") in connection with the Reorganization described in the
Registration Statement. Based upon such investigation as I have deemed
necessary, I am of the following opinion:

1.   The  Fund  has  been  duly  incorporated  and  is  validly  existing  as  a
     corporation in good standing under the laws of the State of Maryland.

2.   The Fund has  authority  to issue the  number  of  shares  of common  stock
     necessary to complete  the  Reorganization  and the shares,  when issued in
     accordance with the terms described in the Registration Statement,  will be
     legally issued, fully paid and non-assessable.

I hereby consent to the filing of this opinion as an exhibit to the Registration
Statement.

Very truly yours,

/s/ Michael D. Roughton

Michael D. Roughton
Counsel