I agree that the "economic reality" of the situation does make PF something like an insurance agent or reseller. I don't know how Randy got around this; maybe he set up the company in a state with relatively lax insurance laws, or found some other way to avoid being recognized as an insurance company.

The point, however, is not PF's legal situation, but whether the policies it sells are sound. I think that the answer to this question is yes. Again: In the event of ff program default/failure, PF's reinsurer, not PF, will be writing the checks.

So... I think we can agree that PF might (might!) be operating in somewhat muddy legal waters, as far as its lack of registration as an insurance company, but that its ability to pay out is fundamentally sound, and has nothing to do with Randy's/PF's cash reserves.

If PF were run by a fly by night operation none of us knew, then I'd agree that the lack of insurance registration would be cause for concern. But I think Randy values his relationship with the vff community too much to bilk them on this.