SecProbe.io

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Blank Rome LLP

1271 Avenue of the Americas

New York, NY 10020

(212) 885-5000 (Phone)

(212) 885-5001 (Facsimile)

www.blankrome.com

January 20, 2023

VIA EDGAR CORRESPONDENCE

Securities and Exchange Commission

100 F Street, NE

Washington, DC 20549

Attention: Samantha A. Brutlag

	Re:	                 Spirit of America Investment
Fund Inc. (Registration No. 333-27925/ 811-08231)

Response to Examiner Comments on Post-Effective

Amendment No. 74

Dear Ms. Brutlag:

This letter responds to your comments on Post-Effective
Amendment No. 74 (“PEA No. 74”) to the Registration Statement on Form N-1A of Spirit of America Investment Fund Inc. (the
“Registrant”). PEA No. 74 seeks to register shares of Spirit of America Utilities Fund, a new series of the Registrant (the
“Fund”).

 1. Comment: Please provide the ticker symbol for each class of shares of the Fund.

Response: The following are the ticker
symbols for Fund’s share classes:

Class A Shares - TICKER: SOAUX

Class C Shares - TICKER: SOCUX

Institutional Shares - TICKER: SOIUX

 2. Comment: Reference is made to the fee table on page 1 of the Prospectus. Please add a footnote to the “Other Expenses”
line item indicating that other expenses are estimated for the current year.

Response: The requested footnote has
been added.

 3. Comment: The Staff notes that the exclusions to the expense waiver listed in footnote 2 to the fee table beginning on page
1 of the Prospectus do not include acquired fund fees and expenses (AFFEs). Please confirm that AFFEs will not be excluded from the expense
waiver or add AFFEs to the list of exclusions.

Response: The Registrant informs the
Staff that AFFEs will be excluded from the expense waiver and the disclosure in the Prospectus has been updated to reflect such exclusion.

January 20, 2023

Page 2

 4. Comment: Reference is made to the fee table beginning on page 1 of the Prospectus. Please clarify that with respect to the
recoupment of any fees or expenses that the Fund’s investment adviser waived and/or reimbursed pursuant to the expense limitation
agreement may only be recouped to the lesser of the current expense limit in effect at the time of recoupment or the prior expense limit
in effect for the period for which the recoupment of fees waived or expenses reimbursed is sought.

Response: The requested clarification
has been added.

 5. Comment: Please provide the final fee table and expense example for the Fund for review at least five business days before
effectiveness of PEA No. 74.

Response: Below is the final fee table
and completed expense example for the Fund:

    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)
    5.75%

    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 and/or Service (12b-1) Fees
    0.25%

    1.00%

    0.00%

    Other Expenses(2)
    0.97%

    0.97%

    0.97%

    Total Annual Fund Operating Expenses
    2.19%

    2.94%

    1.94%

    Fee Waiver and/or Expense Reimbursements(3)
    (0.66)%

    (0.66)%

    (0.66)%

    Total Annual Fund Operating Expenses After Fee Waiver and/or Expense Reimbursement(3)
    1.53%

    2.28%

    1.28%

 (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.

 (2) Other Expenses are estimated for the current year.

 (3) Spirit of America Management Corp. (the “Adviser”) has contractually agreed to waive advisory
fees and/or reimburse expenses under an Operating Expenses Agreement so that the total operating expenses will not exceed 1.53%, 2.28%
and 1.28% of the Class A Shares, Class C Shares and Institutional Shares average daily net assets, respectively, through May 1, 2024.
The waiver does not include front-end or contingent deferred loads, taxes, interest, dividend expenses, brokerage commissions, acquired
fund fees and expenses, expenses incurred in connection with any merger or reorganization or extraordinary expenses such as litigation.
Any amounts waived or reimbursed by the Adviser are subject to reimbursement by the Fund within the following three years, provided the
Fund is able to make such reimbursement and remain in compliance with the lesser of the current

January 20, 2023

Page 3

expense limit in effect at the time
of reimbursement or the prior expense limit in effect for the period for which the reimbursement of fees waived or expenses reimbursed
is sought. The Operating Expenses Agreement may be terminated at any time, by the Board of Directors, on behalf of the Fund, upon sixty
days written notice to the Adviser.

Example: This Example is intended to help you compare
the cost of investing in the Utilities Fund with the cost of investing in other mutual funds. The example assumes that you invest $10,000
in the Utilities 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

    Class A Shares
    $722

    $1,161

    Class C Shares – no redemption
    $231

    $848

    Institutional Shares
    $130

    $545

 6. Comment: Reference is made to the “Principal Investment Strategies” section beginning on page 2 of the Prospectus.
Please include a 50% revenue or assets test for utility related companies.

Response: As requested, the Fund has
added the following test for determining whether a company is in the utilities industry:

“The Fund considers a company to be in the utilities industry
if, at the time of the investment, the Fund determines that at least 50% of the company’s assets or revenues are derived from one
or more utilities or utility related functions.”

 7. Comment: Reference is made to the “Principal Investment Strategies” section beginning on page 2 of the Prospectus.
Please revise this section to clarify whether and which of the three bulleted items will be investments that satisfy and count towards
the 80% names rule policy.

Response: As requested, the referenced
section has been revised to clarify which investments are intended to be included in the 80% names rule policy. Appendix A to this letter
shows the changes made to the “Principal Investment Strategies” section beginning on page 2 of the Prospectus and the “Investment
Strategies of the Fund” section beginning on page 6 of the Prospectus

 8. Comment: Reference is made to the “Principal Risks of Investing in the Utilities Fund” section beginning on page
2 of the Prospectus. Consider adding a small-cap and mid-cap securities risk in this section if the Fun will be invested in these types
of securities.

Response: A small-cap company risk and
a mid-cap company risk has been added.

 9. Comment: Reference is made to the “Investment Strategies of the Fund” section beginning on page 6 of the Prospectus.
The last line of the second paragraph references “other communications media.” Please explain what types of companies would
be included in this category.

January 20, 2023

Page 4

	Response: The Registrant notes that,
in connection with the revisions made in response to comment #7 above, the reference to “other communications media” has been
changed to “other cellular communications,” which is intended to include cellular communications companies.

 10. Comment: Reference is made to the “Investment Strategies of the Fund” section beginning on page 6 of the Prospectus.
The penultimate bullet point at the end of this section states that “MLPs are publicly traded partnerships typically engaged in
the transport, storage, processing, refining, marketing, exploration, production and mining of minerals and natural resources”
(emphasis added). Please explain whether mining of minerals may include non-utility related minerals and if so, will they count towards
the 80% names rule policy.

Response: The Registrant confirms that
mining minerals may include non-utility related minerals but investments in such non-utility related minerals will not count towards the
80% names rule policy.

 11. Comment: Reference is made to the “MANAGEMENT OF THE FUND - Additional Information About the Investment Adviser”
section beginning on page 12 of the Prospectus. Please add disclosure to the fourth paragraph of this section noting that the expense
waiver agreement is subject to exclusions. Likewise, add such disclosure where the expense waiver agreement is discussed in the Statement
of Additional Information (SAI).

Response: The requested disclosure has
been added in the Prospectus and the SAI.

 12. Comment: Reference is made to the “Fundamental Policies of the Utilities Fund” section beginning on page 12 of
the SAI. Please revise the disclosure regarding the Fund’s concentration policy in clause (b) to clarify that the Fund will
concentrate in the utilities industry. It is drafted to impermissibly reserve freedom of action to concentrate.

Response: The disclosure in clause (b)
has been deleted in its entirety and replaced with the following:

 (b) invest 25% or more of its total assets in the securities of issuers conducting their principal business activities in any one industry
(other than the utilities industry, in which the Utilities Fund will invest at least 25% or more of its total assets), except that this
restriction does not apply to securities issued by the U.S. government, agencies, states, municipalities or their instrumentalities

We trust that the foregoing is responsive to your comments.
Please feel free to contact the undersigned at (212) 885-5239 if you have any questions.

Sincerely yours,

/s/ Thomas R. Westle

Thomas R. Westle

APPENDIX A

Principal
Investment Strategies: The Fund seeks to achieve its investment objective by investing, under normal circumstances, at least 80% of
its net assets plus any borrowings in a combination of securities and other assets of utility and utility related companies. These are
companies that are principally engaged in utilities operations such as providing electricity, natural gas, water, and
communication services to the public. internet services, email (electronic mail), data communications,
mobile and cellular infrastructure to the public. The Fund considers a company to be in or related to the utilities industry if, at the
time of the investment, the Fund determines that at least 50% of the company’s assets or revenues are derived from one or more utilities
or utility related functions. As part of its investment process, the Adviser seeks investment opportunities in the utility
industry that may provide steady sources of current income and capital appreciation without incurring unnecessary risks. The Fund’s
assets will be invested primarily in a diverse range of dividend paying common stocks within the utilities industry with
sound and stable corporate structures. The Fund seeks to find utility companies that derive their revenue from utility operations
with strong underlying value. The Fund seeks to select utility companies that have a proven dividend history
with reliable cash flows.

 · In addition, the
Fund may invest up to 20% inof its net assets plus any borrowings
in non-utility related investments, including (i) equity securities, including common stock, preferred stock and convertible
preferred stock of non-utility related companies of any capitalization, whether domestic or foreign,
with potential for accelerating growth, above-average growth or growth potential, increasing or consistent profitability and/or a proven
history of paying consistent dividends. With respect to 20% of the Fund’s net assets, the Fund
may invest in equity securities issued by non-utility related companies.

;
(ii) ·	The
Fund may invest in Master Limited Partnerships (“MLPs”). MLPs,
which are publicly traded partnerships typically engaged in the transport, storage, processing, refining, marketing, exploration,
production and mining of minerals and natural resources. These activities are,
often referred to as the energy infrastructure.

; and (iii) ·	The
Fund may invest in fixed income securities of any grade, as well as non-rated fixed income securities, both short-term
and long-term, including taxable municipal bonds, income producing convertible securities and corporate bonds.

Investment
Strategies of the Fund

The
Fund seeks to achieve its investment objective by investing, under normal circumstances, at least 80% of its net assets plus any borrowings
in a combination of securities and other assets of utility and utility related companies. These are companies that are principally engaged
in utilities operations such as providing electricity, natural gas, water, and communication services
to the public. As part of its investment process, the Adviser seeks investment opportunities
in the utility industry that may provide steady sources of current income and capital appreciation without incurring unnecessary risks.internet
services, email (electronic mail), data communications, mobile and cellular infrastructure to the public.

The
Fund considers a corporationcompany to be in
or related to the utilities industry if, at the time of the investment, the Fund determines that
a significant portionat least 50% of the company’s
assets or revenues are derived from one or more utilities or utility related functions. Issuers
in the utilities industry include firms engaged in the manufacture, production, generation, transmission, sale or distribution of electric,
gas or other types of energy, including water. Other forms of utilities include other sanitary services; and issuers engaged in telecommunications,
including telephone, satellite, cable television, and other cellular communications media.

The
fund emphasizes quality while purchasing securities for the Fund. Investments are selected primarily based on fundamental analysis of
individual issuers. Such analysis may include the issuer's financial condition and market, economic, political, and regulatory conditions.
Other Factors may include analysis of an issuer's revenues, cash flows, earnings outlook, current strategy, and management ability.

Factors
considered for debt instruments may include the instrument’s credit quality, leverage, indenture provisions, management ability,
and ability to meet its current obligations.

As
part of its investment process, the Adviser seeks investment opportunities in the utility industry that may provide steady sources of
current income and capital appreciation without incurring unnecessary risks. The Fund’s
assets will be invested primarily in a diverse range of dividend paying common stocks within the utilities industry with
sound and stable corporate structures. The Fund seeks to find utility companies that derive their revenue from utility operations
with strong underlying value. The Fund seeks to select utility companies that have a proven dividend history
with reliable cash flows.

 · In addition, the
Fund may invest up to 20% inof its net assets plus any borrowings
in non-utility related investments, including (i) equity securities, including common stock, preferred stock