SecProbe.io

CORRESP
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    Phone:
    (212) 885-5205

    Email:
    mmmurphy@blankrome.com

April 22, 2020

FILED VIA EDGAR CORRESPONDENCE

Division of Investment Management

U.S. Securities and Exchange Commission

100 F Street, NE

Washington, DC 20549-4720

Attn: Ms. Samantha Brutlag

 Re: Spirit of America Real Estate Income and Growth Fund (“Real Estate Fund”), Spirit of America Large Cap Value Fund
(“Value Fund”), Spirit of America Municipal Tax Free Bond Fund (“Municipal Tax Free Bond Fund”), Spirit
of America Income Fund (“Income Fund”) and Spirit of America Income & Opportunity Fund (“Opportunity Fund”),
each a series of the Spirit of America Investment Fund, Inc.

Registration Statement on Form N-1A

File Numbers: 333-27925 and 811-08231

Dear Ms. Brutlag:

On behalf of the Real Estate Fund, the
Value Fund, the Municipal Tax Free Bond Fund, the Income Fund and the Opportunity Fund (each a “Fund” and together
the “Funds”), each a series of the Spirit of America Investment Fund, Inc. (the “Company”) this letter
is in response to the comments received on April 14, 2020 from the Staff of the U.S. Securities and Exchange Commission (the “Commission”)
regarding the Company’s Post-Effective Amendment No. 63 to its Registration Statement on Form N-1A filed on February 28,
2020 (the “Registration Statement”) under the Securities Act of 1933 as amended (the “1933 Act”) and the
Investment Company Act of 1940, as amended (the “1940 Act”). We have set forth below, in bold face type, the text of
each comment, followed by the applicable Fund’s response.

All Funds

 1. Please re-order each Fund’s principal risk disclosures in its summary prospectus so that
the four or five most material risks (ie, the most reasonably likely to effect net asset value, yield and total return) are listed
first (in lieu of disclosing them in alphabetical order). See ADI 2019- 08, “Improving Principal Risks Disclosure”
at www.sec.gov.

RESPONSE: Each Fund will list
the risks shown below the Fund’s name on Appendix A hereto (risk headings only) at the beginning of the principal
risks disclosure in such Fund’s summary prospectus, with all other risks to follow alphabetically.

 2. Please consider the significant market impacts of the current COVID-19 pandemic and whether
risk disclosure should be added to the prospectus regarding such impacts.

RESPONSE: The Company filed a
Supplement to the Funds’ Summary Prospectuses and Prospectus (each dated May 1, 2019) with the Commission on March 25, 2020
that contained disclosure regarding the market impacts of COVID-19. The disclosure in such Supplement will be included in the Funds’
Summary Prospectuses and Prospectus that will be filed on April 29, 2020.

 3. Please provide the following for each Fund (in complete, final form): (i) Expense Table &
Expense Example; and (ii) Bar Chart & Performance Table.

RESPONSE: The requested items
for each Fund are provided in Appendix B hereto.

Summary Prospectus – Spirit
of America Real Estate Income and Growth Fund

 4. Revise the disclosure under “Portfolio Manager” on page 5 to only include the information
required by Item 5 of Form N-1A.

RESPONSE: The
Real Estate Fund has revised the disclosure under “Portfolio Manager” on page 5 as set forth below:

Portfolio Manager:
Douglas Revello serves as the Portfolio Manager and is primarily responsible for the day-to-day management of the Real Estate
Fund. Mr. Revello became the Co-Portfolio Manager for the Real Estate Fund effective November 18, 2015 and transitioned to Portfolio
Manager on July 1, 2016. Mr. Revello has been associated with the Adviser since May 18, 2009.

Summary Prospectus – Spirit
of America Large Cap Value Fund

 5. Revise the disclosure under “Portfolio Manager” on page 9 to only include the information
required by Item 5 of Form N-1A.

RESPONSE: The
Value Fund has revised the disclosure under “Portfolio Manager” on page 9 as set forth below:

Portfolio Manager:
Douglas Revello serves as the Portfolio Manager and is primarily responsible for the day-to-day management of the Value Fund.
Mr. Revello has served as the Portfolio Manager of the Value Fund since January 10, 2018. Mr. Revello has been associated with
the Adviser since May 18, 2009.

Summary Prospectus – Spirit
of America Municipal Tax Free Bond Fund

 6. Under “Principal Risks of Investing in the Municipal Tax Free Bond Fund” section
consider adding risk disclosure for certain types of investments (municipal bonds, industrial development bonds, municipal lease
agreements and certificates of participation) which are listed in the Fund’s “Principal Investment Strategy.”

    2

RESPONSE: The
Municipal Tax Free Bond Fund has added the following two risks under the section titled “Principal Risks of Investing in
the Municipal Tax Free Bond Fund”:

 • Industrial Development Bond Risk − Industrial development bonds
are revenue bonds issued by or on behalf of public authorities to obtain funds to finance various public and/or privately operated
facilities. To the extent that investments in the industrial development sector represent a significant portion of the Municipal
Tax Free Bond Fund’s portfolio, it will be sensitive to changes in, and its performance may depend to a greater extent on,
the overall condition of the industrial development sector. These bonds are normally secured only by the revenues from the project
and are not general obligations of the issuer or otherwise secured by state or local government tax receipts. Generally, the value
and credit quality of these bonds are sensitive to the risks related to an economic slowdown.

 • Municipal Securities Risk − Municipal securities risk includes
the risk that issuers of municipal securities (such as municipal bonds and certificates of participation in municipal lease agreements),
including governmental issuers, may be unable to pay their obligations as they come due. The values of municipal securities that
depend on a specific revenue source to fund their payment obligations may fluctuate as a result of actual or anticipated changes
in the cash flows generated by the revenue source or changes in the priority of the municipal obligation to receive the cash flows
generated by the revenue source. The values of municipal securities held by the Municipal Tax Free Bond Fund may be adversely affected
by local political and economic conditions and developments. In addition, income from municipal securities held by the Municipal
Tax Free Bond Fund could be declared taxable because of, among other things, unfavorable changes in tax laws, adverse interpretations
by the Internal Revenue Service or state tax authorities, or noncompliant conduct of an issuer or other obligated party. Loss of
tax-exempt status may cause interest received and distributed to shareholders by the Municipal Tax Free Bond Fund to be taxable
and may result in a significant decline in the values of such municipal securities.

 7. Revise the disclosure under “Portfolio Managers” on page 14 to only include the
information required by Item 5 of Form N-1A.

RESPONSE: The
Municipal Tax Free Bond Fund has revised the disclosure under “Portfolio Managers” on page 14 as set forth below:

    3

Portfolio Managers:
Mark Reilly serves as the Portfolio Manager and is primarily responsible for the day-to-day management of the Municipal Tax
Free Bond Fund. Mr. Reilly has been the Portfolio Manager of the Municipal Tax Free Bond Fund since January 10, 2018. Mr. Reilly
has been associated with the Adviser since November 18, 2015.

Douglas Revello
serves as the Co-Portfolio Manager of the Municipal Tax Free Bond Fund. Mr. Revello served as Portfolio Manager of the Municipal
Tax Free Bond Fund from November 17, 2015 until January 10, 2018 and prior to that he served as Co- Portfolio Manager of the Municipal
Tax Free Bond Fund from May 18, 2009 until November 17, 2015. Mr. Revello has been associated with the Adviser since May 18, 2009.

Summary Prospectus – Spirit
of America Income Fund

 8. Under “Principal Risks of Investing in the Income Fund” section consider adding
risk disclosure for certain types of investments (derivatives and private placements) which are listed in the Fund’s “Principal
Investment Strategy.”

RESPONSE: The
Income Fund has removed the reference to investments in derivatives (futures, options and swaps) from the “Principal Investment
Strategy” section of its summary prospectus. In addition, the Income Fund has added the following risk to the “Principal
Risks of Investing in the Income Fund” section of its summary prospectus:

 • Private Placement Risk  − Private placement risk is the
risk that investments in private placements are illiquid. Privately placed securities may be difficult to sell promptly or at reasonable
prices and might thereby cause the Income Fund difficulty in satisfying redemption requests. Privately placed securities are typically
fair valued and generally have no secondary trading market; therefore, such investments may be more difficult to value than publicly
traded securities. Difficulty in valuing a private placement may make it difficult to accurately determine the Income Fund’s
exposure to private placement investments, which could cause it to invest to a greater extent than permitted in illiquid investments
and subject it to increased risks. Private placement investments may involve a high degree of business and financial risk and may
result in substantial losses. These factors may have a negative effect on the Income Fund’s performance.

 9. Revise the disclosure under “Portfolio Managers” on page 19 to only include the
information required by Item 5 of Form N-1A.

RESPONSE: The
Income Fund has revised the disclosure under “Portfolio Managers” on page 19 as set forth below:

    4

Portfolio Managers:
Mark Reilly serves as the Portfolio Manager and is primarily responsible for the day-to-day management of the Income Fund.
Mr. Reilly became the Co-Portfolio Manager of the Income Fund effective November 18, 2015 and transitioned to Portfolio Manager
on July 1, 2016. Mr. Reilly has been associated with the Adviser since November 18, 2015.

Douglas Revello
serves as Co-Portfolio Manager of the Income Fund and has served in this capacity since May 1, 2018. Mr. Revello has been associated
with the Adviser since May 18, 2009.

Summary Prospectus – Spirit
of America Income & Opportunity Fund

 10. Revise the disclosure under “Portfolio Manager” on page 25 to only include the information
required by Item 5 of Form N-1A.

RESPONSE: The
Opportunity Fund has revised the disclosure under “Portfolio Manager” on page 25 as set forth below:

Portfolio Manager:
Mark Reilly serves as the Portfolio Manager and is primarily responsible for the day-to-day management of the Opportunity Fund.
Mr. Reilly began serving as Portfolio Manager of the Opportunity Fund on January 16, 2020. Mr. Reilly has been associated with
the Adviser since November 18, 2015.

Should you have
any additional questions or comments regarding this letter, please contact me at (212) 885-5205.

    Sincerely,

    /s/ Margaret M. Murphy

    Margaret M. Murphy

    5

Appendix A

Risks To Be Listed at the Beginning
of Principal Risks Section of Summary Prospectus

Spirit of America Real Estate Income and Growth Fund

Industry Risk

REITs Risk

Risk of Loss

Real Estate Risk

MLP Risk

Spirit of America Large Cap Value Fund

Market Risk

Volatility Risk

Risk of Loss

Dividend Payment Risk

Large Capitalization Company Risk

Spirit of America Municipal Tax Free Bond Fund

Interest Rate Risk

Credit Risk

Call Risk

Market Risk

Spirit of America Income Fund

Interest Rate Risk

Credit Risk

Call Risk

Dividend Payment Risk

Market Risk

Spirit of America Income & Opportunity Fund

Interest Rate Risk

Credit Risk

Call Risk

Market Risk

Dividend Payment Risk

Appendix B

Spirit of America Real
Estate Income and Growth Fund

(i) Expense Table & Expense Example

Fees and Expenses of the Real Estate Fund:
This table describes the fees and expenses that you may pay if you buy and hold shares of the Real Estate Fund. The sales charge
you pay for Class A Shares of the Real Estate Fund depends upon the dollar amount invested. You may qualify for sales charge discounts
if you invest at least $250,000 in the Funds comprising Spirit of America Investment Funds, Inc., which include the Real Estate
Fund, the Spirit of America Large Cap Value Fund, the Spirit of America Municipal Tax Free Bond Fund, the Spirit of America Income
Fund, the Spirit of America Income & Opportunity Fund and the Spirit of America Energy Fund, collectively referred to as the
“Spirit of America Investment Funds.” (In addition, the Spirit of America Energy Fund, which is offered in a separate
prospectus, offers sales charge discounts if you invest at least $25,000 in that fund.) More information about these and other
discounts is available from your financial professional and in the sections titled “Additional Information About How to Purchase
Shares” and “Distribution Arrangements – Sale of Class A Shares” of the Real Estate Fund’s prospectus
and in the section titled “How to Purchase Shares” of the Real Estate Fund’s Statement of Additional Information
(“SAI”).

        Shareholder Fees

        (fees paid directly from your investment)

    Class A

Shares
    Class C

Shares
    Institutional

Shares

    Maximum Sales Charge (Load) Imposed on Purchases

(as a percentage of offering price)
    	5.25%
    	None
    	None

    Maximum Deferred Sales Charge (Load)(1)

(as a percentage of net asset value)
    1.00%
    1.00%
    None

        Redemption Fee

        (as a percentage of amount redeemed, if applicable)

    	None
    	None
    	None

        Annual Fund Operating Expenses

        (expenses that you pay each year as a percentage of
        the value of your investment)

    Class A

Shares
    Class C

Shares
    Institutional

Shares

    Management Fees
    	0.97%
    	0.97%
    	0.97%

    Distribution (12b-1) Fees
    	0.30%
    	1.00%
    	0.00%

    Other Expenses
    	0.27%
    	0.27%
    	0.27%

    Total Annual Fund Operating Expenses
    	1.54%
    	2.24%
    	1.24%

 (1) A Contingent Deferred Sales Charge (“CDSC”) of 1.00% may be imposed on redemptions of Class A Shares that were
purchased within one year of the redemption date where an indirect commission was paid. CDSC on Class C Shares applies to shares
sold within 13 months of purchase.

Example: This Example is intended
to help you compare the cost of investing in the Real Estate Fund with the cost of investing in other mutual funds. The example
assumes that you invest $10,000 in the Real Estate Fund for the time periods indicated and that you sell your shares at the end
of those periods. The example also assumes that each year your investment has a 5% return and Fund operating expenses remain the
same. Although your actual costs and returns might be different, your approximate costs of investing $10,000 in the Fund would
be:

        1 year

    3 years

    5 years

    10 years

    Class A Shares
    $673
    $986
    $1,320
    $2,263

    Class C Shares – no redemption
    $227
    $700
    $1,200
    $2,575

    Class C Shares – with redemption
    $327
    $700
    $1,200
    $2,575

    Institutional Shares
    $126
    $393
    $ 681
    $1,500

    B-1

(ii) Bar Chart & Performance Table

Performance Information: The bar
chart and performance table below illustrate the risks of investing in the Real Estate Fund by showing changes in the Real Estate
Fund’s performance from year to year and by showing how the Real Estate Fund’s average annual total returns compare
with those of a broad measure of market performance. The Real Estate Fund’s past performance (before and after taxes) does
not necessarily indicate how the Real Estate Fund will perform in the future.

The bar chart shows the changes in the
annual total returns for each of the last ten calendar ye