[FAF ADVISORS LOGO]



800 Nicollet Mall                                               RICHARD J. ERTEL
BC-MN-HO5F                                                               COUNSEL
Minneapolis, MN 55402                                Direct line: (612) 303-7987
                                                            Fax:  (612) 303-4223


August 14, 2007

Ms. Kimberly Browning                                         VIA EDGAR
Office of Disclosure and Review
Division of Investment Management
Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, DC 20549

Re:     First American Investment Funds, Inc.
        SEC File Nos. 033-16905 and 811-05309
        Response to Staff Comments on Preliminary Proxy Statement (Form PRE 14A)
        Filed with the Commission on August 2, 2007

Dear Ms. Browning:

The purpose of this letter is to respond to the comments that you transmitted by
telephone on August 10, 2007 regarding the preliminary proxy statement for the
above-listed registrant (the "Registrant"), related to International Fund (the
"Fund"), a series of the Registrant. Following is our response to your comments,
which appear in bold-face type below.

1.   PLEASE CLARIFY THAT THE ADVISOR HAS AN EXISTING SUB-ADVISORY RELATIONSHIP
     ON BEHALF OF THE FUND.

     In the third sentence of the first paragraph under "Background" on page 2
     of the proxy statement we indicate that the Fund is currently managed by a
     sub-advisor. In the third paragraph under "Description of the
     Manager-of-Managers Structure" on page 3, there is a discussion of the
     current sub-advisor. In addition to this disclosure, we have made the
     following changes to address the Staff's comment.

     In the first paragraph under "Description of the Manager-of-Managers
     Structure" on page 3 of the proxy statement, the first sentence has been
     modified to read as follows:

         Use of a manager-of-managers structure would permit the Advisor, as the
         Fund's investment manager, to add or replace unaffiliated sub-advisors,
         and enter into and amend sub-advisory agreements with unaffiliated
         sub-advisors on behalf of the Fund without shareholder approval.

     In that same paragraph, the last sentence has been modified to read as
follows:

         If shareholders approve the proposal authorizing a manager-of-managers
         structure for the Fund, the Board would be able to act more quickly and
         with less expense to add or replace unaffiliated sub-advisors, in
         instances in which the Board and the Advisor believe



[FAF ADVISORS LOGO]



         that the addition or replacement would be in the best interests of the
         Fund and its shareholders.

     The second sentence of the following paragraph has also been modified to
read as follows:

         However, the Board will continue to oversee the sub-advisor selection
         process to help ensure that the interests of shareholders are protected
         whenever the Advisor would seek to add or replace a sub-advisor or
         modify a sub-advisory agreement.

2.   DO YOU CONTEMPLATE USING A PERFORMANCE-FEE STRUCTURE TO COMPENSATE
     SUB-ADVISORS TO THE FUND? IF YES, PLEASE PROVIDE DISCLOSURE DESCRIBING SUCH
     STRUCTURE IN THE PROXY STATEMENT. IF NO, PLEASE STATE AS SUCH IN YOUR
     RESPONSE.

     We do not contemplate using a performance fee structure to compensate
sub-advisors to the Fund.

3.   EXPLAIN IN THE PROXY STATEMENT THAT IF FUTURE SUB-ADVISORS AGREE TO MANAGE
     THE FUND'S ASSETS FOR A LESSER FEE THAN THE CURRENT SUB-ADVISOR, THE
     BENEFIT OF SUCH LESSER FEE WILL NOT INURE TO THE BENEFIT OF THE FUND OR ITS
     SHAREHOLDERS GIVEN THAT THE ADVISORY FEE BETWEEN THE FUND AND THE ADVISOR
     WOULD REMAIN UNCHANGED.

     We have added the following disclosure at the end of the second paragraph
     under "Description of the Manager-of-Managers Structure" on page 3 of the
     proxy statement.

         If the Advisor negotiates a decrease in the sub-advisory fee paid to
         any sub-advisor, such a decrease would not affect the investment
         management fee paid by the Fund to the Advisor. The Advisor would
         effectively retain more of the investment management fee for itself.

In connection with the review of the above-referenced filing by the staff of the
Securities and Exchange Commission (the "Commission"), the Registrant hereby
acknowledges that:

     1.  The Registrant is responsible for the adequacy and accuracy of the
         disclosure in the filing.
     2.  Staff comments or changes to disclosure in response to staff comments
         in the filing reviewed by the
         staff do not foreclose the Commission from taking any action with
         respect to the filing.
     3.  The Registrant may not assert staff comments as a defense in any
         proceeding initiated by the Commission or any person under the federal
         securities laws of the United States.

If you need anything further, please contact me at your earliest convenience at
612-303-7987. Thank you for your help.


                                           Sincerely,

                                           /s/ Richard J. Ertel

                                           Richard J. Ertel
                                           Assistant Secretary to the Registrant