Why is the Change-Fee Waiver not considered to be insurance?
A. There are three characteristics of our program that place it outside of the legal definition of insurance in all U.S. jurisdictions: our benefits are not contingent on any adverse event, our customers pay no premiums, and our customers are not reimbursed for losses (because there are no losses). The Change-Fee Waiver is just one component of our service, which all our customers receive.