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OCR: id at 327. Accord Jacobson t John Hancock Mut. Life Ins. Co 655 ] Supp 1290 withdrawn pursuant to settlement 662 Supp 1103 1112-13 Conn. 1987) A5 Iudge Posner analysis in Peoria indicated, the decision Congress t0 create A exemption from ERISA's fiduciary rules for certain types of insurance contracts was hardly surpris- ing The Seventh Circuit relied on a long line of cases which anal vze the realities of insurance contracts. In SEG Variable Annuity Life Irs. 1 America. 359 U.S 65 {1959} "VALIC this Court had held that variable annuity contracts issued by insurance companies are 'investment contracts" and not exempt "insurance contracts' under the Securities Act. Similarly, in SEC all- Untted Benefit Life Iyrarce Co. this Court trejected an or -nothing' analysis of an insurance contract w ...