Nor has the Court manifested lately any disposition to depart from this
rule. In Sovereign Camp _v._ Bolin[110] it declared that a State in
which a certificate of life membership of a foreign fraternal benefit
association is issued, which construes and enforces said certificate
according to its own law rather than according to the law of the State
in which the association is domiciled denies full faith and credit to
the association's charter embodied in the statutes of the domiciliary
State as interpreted by the latter's court. "The beneficiary certificate
was not a mere contract to be construed and enforced according to the
laws of the State where it was delivered. Entry into membership of an
incorporated beneficiary society is more than a contract; it is entering
into a complex and abiding relation and the rights of membership are
governed by the law of the State of incorporation. [Hence] another
State, wherein the certificate of membership was issued, cannot attach
to membership rights against the society which are refused by the law of
domicile." Consistently therewith, the Court also held, in Order of
Travelers _v._ Wolfe,[111] that South Dakota, in a suit brought therein
by an Ohio citizen against an Ohio benefit society, must give effect to
a provision of the constitution of the society prohibiting the bringing
of an action on a claim more than six months after disallowance by the
society, notwithstanding that South Dakota's period of limitation was
six years and that its own statutes voided contract stipulations
limiting the time within which rights may be enforced. Objecting to
these results, Justice Black dissented on the ground that fraternal
insurance companies are not entitled, either by the language of the
Constitution, or by the nature of their enterprise, to such unique
constitutional protection.

INSURANCE COMPANY, BUILDING AND LOAN ASSOCIATION--CONTRACTUAL
RELATIONSHIPS

Whether or not distinguishable by nature of their enterprise, stock and
mutual insurance companies and mutual building and loan associations,
unlike fraternal benefit societies, have not been accorded the same
unique constitutional protection; and, with few exceptions,[112] have
had controversies arising out of their business relationships settled by
application of the law of the forum State. In National Mutual B. & L.
Asso. _v._ Brahan,[113] the principle applicable to these three forms of
business organization was stated as fo