0001193125-09-094271 Sample Contracts

PURCHASE AGREEMENT
Purchase Agreement • April 30th, 2009 • Spirit of America Investment Fund Inc

Spirit of America Investment Fund, Inc. (the “Company”), a Maryland Corporation, on behalf of the Spirit of America Income Fund (the “Portfolio”) and David Lerner (the “Purchaser”) hereby agree as follows:

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SPIRIT OF AMERICA INVESTMENT FUND, INC.
Investment Advisory Agreement • April 30th, 2009 • Spirit of America Investment Fund Inc

This letter 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 Fund under the Agreement and shall be subject to the terms set forth under the Agreement unless otherwise provided herein. The Adviser shall be compensated for services rendered under the Agreement as is consistent with the Agreement, including but not limited to Exhibit A to the Agreement as amended on December 31, 2008 and attached hereto.

UNDERWRITING AGREEMENT
Underwriting Agreement • April 30th, 2009 • Spirit of America Investment Fund Inc • New York

This Agreement, dated as of the 31st day of December 2008, made by and between Spirit of America Investment Fund, Inc. (the “Fund”), a corporation duly organized under the laws of the state of Maryland and operating as a registered investment company under the Investment Company Act of 1940, as amended (the “Act”); and David Lerner Associates, Inc. (“DLA”), a registered broker-dealer existing as a corporation duly organized and existing under the laws of New York (together, the “Parties”).

TRANSFER AGENCY SERVICES AGREEMENT
Transfer Agency Services Agreement • April 30th, 2009 • Spirit of America Investment Fund Inc

THIS AGREEMENT is approved and ratified on January 27, 2009 by and between PNC GLOBAL INVESTMENT SERVICING (U.S.) INC., a Massachusetts corporation (“PNC”) and SPIRIT OF AMERICA INVESTMENT FUND, INC., a Maryland corporation (the “Fund”). Capitalized terms not otherwise defined shall have the meanings set forth in Appendix A.

AMENDMENT TO CUSTODIAN SERVICES AGREEMENT
Custodian Services Agreement • April 30th, 2009 • Spirit of America Investment Fund Inc

This Amendment dated as of December 31, 2008 is made by and between the Spirit of America Investment Fund, Inc. (the “Fund”) and PFPC Trust Company (“PFPC Trust,” collectively with the Fund, the “Parties”).

FIN 48 TAX SERVICES AGREEMENT
Fin 48 Tax Services Agreement • April 30th, 2009 • Spirit of America Investment Fund Inc

THIS FIN 48 TAX SERVICES AGREEMENT (“Agreement”), is approved and ratified on January 27, 2009 by and between PNC GLOBAL INVESTMENT SERVICING (U.S.) INC., a Massachusetts corporation (“PNC”) and SPIRIT OF AMERICA INVESTMENT FUND, INC., a Maryland corporation (“Fund”).

ADMINISTRATION AND ACCOUNTING SERVICES AGREEMENT
Administration and Accounting Services Agreement • April 30th, 2009 • Spirit of America Investment Fund Inc

THIS AGREEMENT is approved and ratified on January 27, 2009 by and between PNC GLOBAL INVESTMENT SERVICING (U.S.) INC., a Massachusetts corporation (“PNC”) and SPIRIT OF AMERICA INVESTMENT FUND, INC., a Maryland corporation (the “Fund”). Capitalized terms not otherwise defined shall have the meanings set forth in Appendix A.

SPIRIT OF AMERICA INVESTMENT FUND, INC.
Operating Expenses Agreement • April 30th, 2009 • Spirit of America Investment Fund Inc

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.

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