SEC v. Mutual Benefits Corp.

MBC (defendant) purchased life insurance policies from terminally ill individuals, continued paying premiums, and sold interests in the policies to investors who profited if the insured died before the estimated death date, though MBC often performed its life-expectancy evaluations after closing the sale rather than beforehand; the SEC (plaintiff) sued for failure to register these interests as securities, and the district court found them to be investment contracts, with MBC appealing that only pre-purchase efforts were involved, insulating the contracts from Howey's third-party-efforts requirement.