SPIRIT OF AMERICA MANAGEMENT CORP

SOA Premier Assets' advisory business has two components. First, they offer portfolio management services to mutual funds, with their only current investment company client being Spirit of America Investment Fund, Inc. These services are provided through an investment advisory agreement, and further details can be found in the prospectus of Spirit of America Investment Fund, Inc. Second, SOA Premier Assets offers the SOA Premier Assets Program to retail investors. The terms and conditions of the advice provided to clients participating in the SOA Premier Assets Program are detailed in Items 4 and 6 of the brochure.

SOA Premier Assets employs distinct investment strategies based on risk tolerance. When selecting investments for each Strategy, SOA Premier Assets follows certain standard methods of analysis such as researching possible investments and analyzing the holdings and/or financial data applicable to the investment. For mutual funds, they prioritize funds with at least $1 billion in assets under management, lower expense ratios, a performance history, primarily U.S.-issued securities, and avoidance of leverage or derivatives. For index-based ETFs, they favor those tracking U.S. indices (e.g., S&P 500) without leverage and with lower expense ratios. The Conservative Strategy focuses on mutual funds and ETFs holding large-cap equities, growth and value stocks, and taxable municipal bonds, corporate bonds, treasury securities, preferred securities, and dividend-paying equities. The Moderate Strategy balances equity and fixed income securities, including small, mid, and large-cap issuers, and may also include taxable municipal bonds, corporate bonds, treasury securities, preferred securities, and dividend-paying equities. Another strategy invests in mutual funds and ETFs holding tax-free municipal bonds with an investment-grade rating of "BBB" or higher, potentially including state-specific bonds for additional tax exemptions.

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