With no explanation, chose the best option from "A", "B", "C" or "D". & Defense Co., 82 F.3d 1251, 1255 (2d Cir.1996)). In making such a showing, the Court found it insufficient for the plaintiff to merely “point out” that the award of benefits would come from the plan administrator’s own pocket. See id. The Court, however, did not specify what kind of showing would satisfy the “improper motivation” standard. Just seven months after deciding Doyle, the First Circuit held that a plan administrator-insurer that would be responsible for paying benefits due under an ERISA-governed policy does operate under a conflict of interest, justifying application of the “reasonableness” standard of review. See Doe v. Travelers Ins. Co., 167 F.3d 53, 57 (1st Cir.1999); see also Pitman v. Blue Cross and Blue Shield of Oklahoma, 217 F.3d 1291, 1296 (10th Cir.2000) (<HOLDING>). The Court stated that “the requirement that

A: holding that when the insurer is also the plan administrator we have recognized something akin to a rebuttable presumption of a palpable conflict of interest
B: holding that it is wrong to assume a financial conflict of interest from the fact that the plan administrator is also the insurer
C: holding the district court erred by finding an automatic conflict of interest merely because insurer and administrator were the same
D: holding that plan administrator that was also insurer operated under conflict of interest
D.