Excerpt: [G]roup annuity contracts, such as those described above, that provide for reasonable rates of return (taking into account any fees and costs charged against the contract), guaranteed for fixed periods, as well as a right to convert the funds into annuities at the guaranteed annuity purchase rates set forth in the contract, would, in the absence of other guidance, appear to constitute 'guaranteed benefit policies' within the meaning of section 401(b)(2) of ERISA.