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OCR: providing variable rate return to plans. and that, as to "at Ieast one component of GAC 50 Hancock's investment per formance clearly dee the amount of Funds available the plan and its participants" P DOL Advisory Opinion 83. -51A states in part: conventional separate account (which holds oontribu- tions received from plan and provides for the crediting of income on such amounts based upon the investment the separate account} not he considered to maintained in connection with fixed contractual obligation of the irsurance com- parry merely because assets Qt the separate account are ultimately applied to provide fixed annuities par- ticipants and the assets such separate account should be considered t be plan assets H.A. 112 From this opinion, the below concluded that the DOL "appear to take ...