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EX-99.CODE ETH
CODE OF ETHICS OF SPIRIT OF AMERICA INVESTMENT FUND, INC.,
SPIRIT OF AMERICA MANAGEMENT CO. AND
SSH SECURITIES RULE 17J-1 POLICY
GENERAL
This Code of Ethics of Spirit of America Investment Fund, Inc. (the "Fund"),
Spirit of America Management Co. (the "Advisor") and SSH Securities (the
"principal underwriter") is adopted on March 7, 2000, pursuant to the
requirements of Rule 17j-1 under the Investment Company Act of 1940, as amended
(the "Act"), and shall apply to each currently existing and all future series of
shares of the Fund. Each reference to "Fund" in the Code of Ethics shall be
deemed to apply to each of the currently existing and all future separate series
of shares of the Fund.
Rule 17j-1(a) under the Act makes it unlawful for any employee, officer or
director of a registered investment company or its investment adviser or
principal underwriter, and certain other affiliated persons of such entities, in
connection with the purchase or sale, directly or indirectly, by such person of
a security "held or to be acquired" by such investment company, to (i) employ
any device, scheme or artifice to defraud such investment company, (ii) make to
such investment company any untrue statement of a material fact or omit to state
to the investment company a material fact necessary in order to make the
statements made, not misleading, (iii) engage in any act, practice or course of
business which operates or would operate as a fraud or deceit upon the
investment company, or (iv) engage in manipulative practice with respect to the
investment company.
The underlying general principles of this Code of Ethics are that "Access
Persons," (as defined below) in conducting their personal securities
transactions, (i) owe a fiduciary duty to shareholders of an affiliated
investment company and at all times have a duty to place the interests of such
shareholders ahead of their personal interests, (ii) are obligated to conduct
all personal "securities" transactions in accordance with this Code of Ethics
and in a manner so as to avoid any actual or potential conflict of interest or
abuse of such person's position of trust and responsibility, and any appearance
of such conflict of interest or abuse of position, and (iii) should not take
inappropriate advantage of their positions.
I. DEFINITIONS.
A. "Access Person" means any officer, director or Advisory Person (as
defined below) of the Fund or its investment adviser and principal
underwriter
B. "Advisory Person" means: (a) any officer, director or employee of the
Fund or its investment adviser or of any company in a control
relationship with the Fund who, in connection with his/her regular
functions or duties, makes, participates in, or obtains information
regarding the purchase or sale of a Covered Security (as defined below)
by the Fund, or whose functions relate to the making of any
recommendations with respect to such purchases or sales; (b) any natural
person in
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a control relationship with the Fund or its investment adviser who
obtains information with respect to the Fund regarding the purchase or
sale of Covered Securities.
C. A security is "being considered for purchase or sale" when a
recommendation to purchase or sell a security has been made and
communicated, and, with respect to the person making the recommendation,
when such person seriously considers making such a recommendation.
D. "Beneficial Ownership" shall have the meaning ascribed thereto under
Section 16 of the Securities Exchange Act of 1934, as amended, and the
rules and regulations thereunder. Generally, an employee is regarded as
having a beneficial interest in those securities held in his or her
name, the name of his or her spouse and the names of his or her minor
children who reside with him or her. A person may be regarded as having
a beneficial interest in the securities held in the name of another
person (individual, partnership, fund, trust or another entity) if, by
reason of a contract, understanding or relationship he or she obtains or
may obtain therefrom benefits substantially equivalent to those of
ownership.
E. "Control" means the power to exercise a controlling influence over the
management or policies of the fund, unless such power is soley the
result of an official position with the fund.
F. "Covered Security" shall have the meaning set forth in Section 2(a)(36)
of the Act, including options, warrants and futures contracts, except it
does not include securities issued by the Government of the United
States or by federal agencies and which are direct obligations of the
United States, bankers' acceptances, certificates of deposit, commercial
paper (and such other money market instruments as may be designated from
time to time by the Fund's Board of Directors) and shares of registered
open-end investment companies.
G. "Initial Public Offering" or "IPO" means an offering of securities
registered under the Securities Act of 1933, the issuer of which,
immediately before the registration, was not subject to the reporting
requirments of Sections 13 or 15(d) of the Securities Exchange Act of
1934.
H. "Limited Offering" is an offering that is exempt from registration under
the Securities Act of 1933 pursuant to Sections 4(2) or 4(6) or pursuant
to Rules 504, 505 or 506 under the Securities Act of 1933.
I. "A security held or to be acquired" means any Covered Security which,
within the most recent 15 days: (i) is or has been held by the Fund; or
(ii) is being or has been considered by the Fund or its investment
adviser for purchase by the Fund, including an option to purchase or
sell a Security.
II. PROHIBITONS/RESTRICTIONS.
A. It is prohibited for an Access Person of the Fund:
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(1) In connection with the purchase or sale, directly or indirectly,
by such person of a Covered Security held or to be acquired by
the Fund:
(i) to employ any device, scheme or artifice to defraud the
Fund;
(ii) to make to the Fund any untrue statement of a material fact
or omit to state to the Fund a material fact necessary in
order to make the statements made, in light of the
circumstances under which they are made, not misleading;
(iii) to engage in any act, practice, or course of business which
operates or would operate as a fraud or deceit upon the
Fund; or
(iv) to engage in any manipulative practice with respect to the
Fund.
(2) to purchase or sell, directly or indirectly, any Covered Security
in which he/she has, or by reason of such transaction acquires,
any direct or indirect beneficial ownership and which to his/her
actual knowledge, or should have known, at the time of such
purchase or sale:
(i) is being considered for purchase or sale by the Fund; or
(ii) is then being purchased or sold by the Fund
unless such transaction is in conformance with the Trade
Allocation Procedures or the Policy on Insider Trading and Code
of Ethics of the investment adviser, Spirit of America Management
Corp.
B. Pre-clearance of Investments in IPOs and Limited Offerings.
Advisory Persons must obtain approval from the Compliance Officer of the
Fund before directly or indirectly acquiring beneficial ownership in any
securities in an IPO or a Limited Offering. The Compliance Officer, in
determining whether approval should be given, will take into account,
among other factors, whether the investment opportunity should be
reserved for the Fund and whether the investment opportunity is being
offered to the access person by virtue of his/her position with the
Fund.
Any approval given under this paragraph will remain in effect until the
earliest of (i) its revocation, (ii) 9:30 a.m. the following business
day or (iii) the moment the Advisory Person learns that the information
in the Pre-clearance Form is not accurate. If the order for the
securities transaction is not placed within that period, a new
authorization must be obtained before the securities transaction order
is placed.
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III. PROCEDURAL MATTERS.
A. A Compliance Officer shall be appointed to receive reports under this
Code of Ethics and to otherwise oversee implementation and administration of the
Code. The Compliance Officer of the Fund shall:
(1) Identify and maintain a current list of all Access Persons and
shall inform the same of their reporting obligations under this
Code. The Compliance Officer shall institute procedures to ensure
that all reporting Access Persons have submitted reports,
confirmations or statements in a timely manner. The Compliance
Officer may delegate this function to one or more other persons.
(2) Furnish a copy of this Code to each Access Person of the Fund
annually so each such Access Person must certify that he/she has
read and understand said Code of Ethics and recognizes that he/she
is subject to the principles and prohibitions contained therein.
(3) Notify each such Access Person of his/her obligation to certify
annually that he/she has complied with the requirements of this
Code of Ethics.
(4) Notify each such Access Person of his/her obligation to file
reports as provided by Section IV of this Code.
(5) Report to the Board of Directors the facts contained in any reports
filed with the Compliance Officer pursuant to Section IV of this
Code when any such report indicates that an Access Person engaged
in a transaction in a security held or to be acquired by the Fund.
(6) Review all holdings reports and make prior approval determinations
and to determine whether there has been a violation or
non-compliance with the Code.
(7) The Compliance Officer shall report to the Directors at least
annually and in writing, any issues arising under this Code since
the last report, including, but not limited to, information about
any material violations of this Code and any sanctions imposed.
Such report shall also certify that the Fund and the Advisor each
have adopted procedures reasonably necessary to prevent Access
Persons from violating this Code.
(8) Maintain the records required by paragraph (f) of Rule 17j-1.
B. All reports disclosing personal securities transactions or holdings,
and any other information filed pursuant to this Code, shall be treated
as confidential, but are subject to review as provided herein and by
representatives of the Securities and Exchange Commission.
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IV. REPORTING.
A. Initial Holdings Report. No later than 10 days after a person becomes an
Access Person, that person (except as described in Section V below)
shall report to the Compliance Officer the following information on the
form attached hereto as Exhibit B:
(1) the title, number of shares and principal amount of each Covered
Security in which the Access Person had any direct or indirect
Beneficial Ownership;
(2) the name of any broker, dealer or bank with whom the Access Person
maintained an account in which any securities were held for the
direct or indirect benefit of the Access Person as of the date the
person became an Access Person; and
(3) the date that the report is filed.
B. Quarterly Transaction Reports.
(1) Every Access Person shall report to the Fund the information
described in Section IV(B)(2) of this Code with respect to
transactions in any Covered Security in which such Access Person
has, or by reason of such transaction acquires, any direct or
indirect Beneficial Ownership in the Covered Security on the form
attached hereto as Exhibit A.
(2) Each report shall be made not later than 10 calendar days after the
end of the calendar quarter in which the transaction to which the
report relates was effected, and shall contain the following
information:
(i) the date of the transaction, the title and the number of
shares, and the principal amount of each Security involved;
(ii) the nature of the transaction (i.e., purchase, sale or any
other type of acquisition or disposition);
(iii) the price of the Covered Security in which the transaction
was effected; and
(iv) the name of the broker, dealer or bank with or through whom
the transaction was effected; and
(v) the date that the report is filed.
(3) In lieu of filing quarterly reports, copies of confirmations and
periodic (monthly/quarterly) brokerage account statements may be
filed with the Compliance officer
(4) Any such report may contain a statement that the report shall not be
construed as an admission by the person making such report that
he/she has any direct or
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indirect Beneficial Ownership in the Covered Security to which the
report relates.
C. Annual Holdings Reports. Thirty days after the fund's fiscal year end,
each Access Person must submit the following information (which
information must be current as of a date no more than 30 days before the
report is submitted):
(1) the title, number of shares and principal amount of each Covered
Security in which the Access Person had any direct or indirect
Beneficial Ownership;
(2) the name of any broker, dealer or bank with whom the Access Person
maintained an account in which any securities are held for the
direct or indirect benefit of the Access Person; and
(3) the date that the report is filed by the Access Person.
V. EXCEPTIONS TO REPORTING REQUIREMENTS
A. A Director who is not an "interested person" (as defined in the Act) of
the Fund, and who would be required to make a report solely by reason of
his or her position as Director, is not required to file an Initial
Report or an Annual Report. In addition, a Director who is not an
"interested person" of the Fund need only report a transaction in a
Covered Security if such Director, at the time of that transaction,
knew, or in the ordinary course of fulfilling his/her official duties as
a Director of the Fund, should have known, that during the 15-day period
immediately preceding or following the date of the transaction by the
Director, such Covered Security is or was purchased or sold by the Fund
or was being considered for purchase or sale by the Fund or by its
investment adviser.
B. A person need not make an Initial Report, Quarterly Report or Annual
Report with respect to transactions effected for, and any Covered
Security held in, any account over which that person has no direct or
indirect influence or control, or which are non-volitional on the part
of either the Access Person or the Fund.
C. A person need not make an Initial Report, Quarterly Report or Annual
Report with respect to transactions which are part of an automatic
dividend reinvestment plan or purchases effected upon the exercise of
rights issued by an issuer pro rata to all holders of a class of its
securities, to the extent such rights were acquired from such issuer,
and sales of such rights so acquired.
D. A person need not make an Initial Report, Quarterly Report or Annual
Report with respect to purchases or sales of Covered Securities which
are not eligible for purchase or sale by the Fund
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VI. VIOLATIONS.
Upon being apprised of facts which indicate that a violation of this Code
may have occurred, the Board of Directors of the Fund shall determine
whether, in their judgment, the conduct being considered did in fact
violate the provisions of this Code. If the Board of Directors determines
that a violation of the Code has occurred, the Board may impose such
sanctions as it deems appropriate in the circumstances. If the person whose
conduct is being considered by the Board is a Director of the Fund, he/she
shall not be eligible to participate in the judgment of the Board as to
whether a violation exists or in whether, or to what extent, sanctions
should be imposed.
VII. CONFIDENTIALITY OF SECURITIES TRANSACTIONS REPORTS.
All personal securities transactions reports disclosing personal
securities holdings, and any other information filed pursuant to this
Code, shall be treated as confidential, but are subject to review as
provided herein and by representatives of the Securities and Exchange
Commission.
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LIST OF ACCESS PERSONS OF SPIRIT OF AMERICA INVESTMENT FUND, SPIRIT OF
AMERICA MANAGEMENT CORP. AND SSH SECURITIES, INC.
David Lerner (a)
Daniel Lerner (a)
Allen Kaufman (a)(d)
Thomas P. Reynolds (a)(d)
Stanley Thune (a)(d)
Daniel E. Chafetz (c)
Ronald Weiss (c)
(a) Director of the Fund
(b) Officer of the Fund
(c) Advisory Person
(d) Not an "interested person" as defined; trading reports not required
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Exhibit A
SPIRIT OF AMERICA INVESTMENT FUND INC.
SPIRIT OF AMERICA MANAGEMENT CO.
AND
SSH SECURITIES
PERSONAL SECURITIES TRANSACTIONS REPORT
CALENDAR QUARTER ENDED ___/___/___
During the calendar quarter referred to above, the following transactions were
effected in securities of which I had, or by reason of such transaction
acquired, direct or indirect beneficial ownership, and which are required to be
reported pursuant to the Fund's Code of Ethics.
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<Caption>
NUMBER OF NATURE OF
SHARES TRANSACTION BROKER/DEALER OR
DATE OF OF PRINCIPAL (PURCHASE, BANK THROUGH
NAME OF SECURITY TRANSACTION SECURITY AMOUNT SALE, OTHER) PRICE WHOM EFFECTED
- ---------------------------- --------------- -------------- --------------- --------------- ------------ --------------------
</Table>
During the quarter, I established accounts of securities held for my direct or
indirect benefit at the banks/brokers/dealers below:
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<Caption>
NAME OF BANK/BROKER/DEALER DATE ACCOUNT ESTABLISHED
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</Table>
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THIS REPORT (i) EXCLUDES TRANSACTIONS WITH RESPECT TO WHICH I HAD NO DIRECT OR
INDIRECT INFLUENCE OR CONTROL AND (ii) IS NOT AN ADMISSION THAT I HAVE DIRECT OR
INDIRECT BENEFICIAL OWNERSHIP IN THE SECURITIES LISTED ABOVE.
Date: Signature:
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Print Name:
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Exhibit B
SPIRIT OF AMERICA INVESTMENT FUND INC.
SPIRIT OF AMERICA MANAGEMENT CO.
AND
SSH SECURITIES
PERSONAL SECURITIES TRANSACTIONS REPORT
PLEASE CHECK ONE: INITIAL REPORT
ANNUAL REPORT
I hold direct or indirect beneficial ownership of the securities listed below:
(PLEASE CONTINUE LIST ON PAGE TWO OF THIS REPORT OR ATTACH ADDITIONAL PAGES IF
NEEDED)
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NUMBER OF
SHARES OF BROKER/DEALER, BANK OR OTHER ENTITY WITH WHICH
NAME OF SECURITY SECURITY SECURITIES ARE HELD
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</Table>
I maintain accounts of securities held for my direct or indirect benefit at the
banks/brokers/dealers below:
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THIS REPORT (i) EXCLUDES SECURITIES WITH RESPECT TO WHICH I HAD NO DIRECT OR
INDIRECT INFLUENCE OR CONTROL AND (ii) IS NOT AN ADMISSION THAT I HAVE DIRECT OR
INDIRECT BENEFICIAL OWNERSHIP IN THE SECURITIES LISTED ABOVE.
Date: Signature:
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Print Name:
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