ABC News also seems to think the
Award Guard/Privilege Flyer product is "
insurance*" too:
http://i.abcnews.com/sections/busine...il_020606.html
* Insurance is defined as "a contract whereby one, for consideration, undertakes to indemnify another or to pay a specified or ascertainable amount or benefit upon determinable risk contingencies, and includes annuities." - Colorado Revised Statutes