Note that nowhere on the AwardGuard website http://www.privilegeflyer.com/awardguard/ is the word "insurance" used - it's called a benefit, which may take it out of the realm of regulation.

Also, remember Randy's statement:

"When we first put the program together, we actually underwrote the first insurance in the Lloyd's insurance market in London with some seasoned insurance executives putting together the layers of insurance needed for such a program. That was quite interesting though the actual coverage is different today." That last sentence may be a subtle way of saying that there is no underwriter for the current coverage - especially since it's not "insurance".

If you're looking for financials, I don't think there's much chance. AG is part of PrivilegeFlyer, which looks like it's owned by Frequent Flyer Services, a privately held company. http://www.frequentflyerservices.com/whoweare.shtml

Also, on the AG website, it states that "Claims for all programs which cease operation during the same membership year will be applied towards one $7,500 aggregate award liability." Yes, Randy states that they're still paying out claims on Midway, but I wonder if the $7,500 aggregate liability per program was instituted after the Midway collapse. The $7,500 limit may be why AG goes with a flat fee instead of a mileage-based fee.

So if you happen to be sitting with a million+ miles in an FF account, a $7,500 limit won't give you a lot of protection, especially if you use them for upgrades.