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OCR: com ponents, and that, in the "accumulation phase under the con- the tract in issue was non-exempt investment contract Securities Act: First, we do you agree with the Court of Appeals that the "Flexible Fund contract must be characterized entirety Two entirely distinct promises cluded in the contract and their operation separated fixed point in time. United Benefit, 387 U.S at 207 The Court also provided a basis for distinguishing between the insura and investment aspects of contracts like GAC .50 After analyzing the role of an insurer in pricing and establishing conventional annuity the Court noted the distinct difference ip the role an insurance company assumes during the accumula- tion phase: The "Flexible program completely reverses the role of the insurer during the accumulation perio ...