Agreed, presuming all the i's are dotted and t's are crossed, more power to him and the company.

If it is as you state, doesn't that then make this program insurance- or at least make priviegeflyer an insurance agent? I'm only familiar with the laws governing insurance co's in a few states, but I know I went through hoops to get a "no action" letter from the attorney general or commerce commissioner of a few states once they concluded that we were not insurance. I did this before engaging in business in such states, lest the hand of the law be smacked down upon me.