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OCR: The DOLs adoption of Hancock's and the ACLI's position also ignores this Court's analvsis of the hybrid nature of invest ment vehicles : such as GAC 50. SEC United Benefit Life ITS Co. 387 U.S 202 {1967} "United Benefit"}. There as here, the contract in issue contained an optional annuity purch pro- vision which permitted the purchaser to convert his interest separate account "Flexible Fund" into a life annuity This Court concluded that, even with this feature and 'guarantee that a certain amount of fixed -amount payment life annuity will he available maturity, the contract was ar investment cont r&ct within the scope of the Securities Act, and not an exempt in- surance contract 206. this Court noted, the "fixed -payment benefits are adjusted to reflect the number of dollars available 25 o ...