SPIRIT OF AMERICA INVESTMENT FUND, INC.

Exhibit (h)(xi)

SPIRIT OF AMERICA INVESTMENT FUND, INC.

000 Xxxxxxx Xxxxxxxx

Xxxxxxx, Xxx Xxxx 00000

December 31, 0000

Xxxxxx xx Xxxxxxx Management Corp.

000 Xxxxxxx Xxxxxxxx

Xxxxxxx, Xxx Xxxx 00000

To Whom It May Concern,

Reference is made to the Operating Expenses Agreement (the “Agreement”) between Spirit of America Investment Fund, Inc. (the “Company”) and Spirit of America Management Corp. (the “Advisor”) dated February 24, 1999.

This writing is to provide notice of the addition of a new series under the Company: Spirit of America Income Fund (the “New Fund”). The New Fund is to be considered a Series under the Agreement and shall be subject to the terms set forth under the Agreement unless otherwise provided herein.

The Company requests that you limit the New Fund’s Operating Expenses (as that defined in Paragraph 2 of the Agreement) to the annual rate of total Operating Expenses specified in the Amended Appendix A to the Agreement attached hereto.

This amendment to the Agreement will remain in effect until April 30, 2010 and may be renewed by the Board of Directors annually thereafter.

If the foregoing is in accordance with your understanding, please so indicate by signing and returning to us the enclosed copy hereof.

Sincerely,

Spirit of America Investment Fund, Inc.

Xxxxx Xxxxxx

President

Spirit of America Management Corp.

Accepted:

Amended Appendix A

This Amended Appendix A, dated as of December 31, 2008, is Exhibit A to the Operating Expense Agreement dated February 24, 1999 between Spirit of America Investment Fund, Inc. and Spirit of America Management Corp.

SPIRIT OF AMERICA INVESTMENT FUND, INC.

Fund		Fee
Spirit of America Real Estate Income and Growth Fund Class A		1.97	%
Spirit of America Real Estate Income and Growth Fund Class B		2.67	%
Spirit of America Large Cap Value Fund		1.97	%
Spirit of America High Yield Tax Free Bond Fund		0.90	%
Spirit of America Income Fund		1.10	%