SPIRIT OF AMERICA MANAGEMENT CORP/NY

Report of Holders of Securities

Report of Holders of Securities

Report of Holders of Securities

Report of Holders of Securities

Report of Holders of Securities

Report of Holders of Securities

Report of Holders of Securities

Report of Holders of Securities

Report of Holders of Securities

Report of Holders of Securities

Report of Holders of Securities

Report of Holders of Securities

Report of Holders of Securities

Report of Holders of Securities

Report of Holders of Securities

Report of Holders of Securities

Report of Holders of Securities

Report of Holders of Securities

Report of Holders of Securities

Report of Holders of Securities

Application for an order under the Investment Company Act (exemptive relief)