--000000000000b94db5062cb60bd8 Content-Type: text/plain; charset="UTF-8" Content-Transfer-Encoding: quoted-printable Perfect - thank you! Will Reid Partner * Please note my email has changed: * wreid@thekey.com 513-707-2304 TheKey.com [image: TheKey] On Mon, Jan 27, 2025 at 2:13=E2=80=AFPM Steve Koyanagi wrote: > Yes; updated in section 7 on the attached. The Exhibit remains the same > (also attached). > > On Mon, Jan 27, 2025 at 10:48=E2=80=AFAM Will Reid wro= te: > >> That=E2=80=99s fine. Could you add some language to cover this? >> >> Thanks >> >> Will Reid >> Partner >> * Please note my email has changed: * >> wreid@thekey.com >> 513-707-2304 >> TheKey.com >> [image: TheKey] >> >> >> On Mon, Jan 27, 2025 at 12:55=E2=80=AFPM Steve Koyanagi >> wrote: >> >>> Hi Will, >>> >>> Based on additional review of how broad the Ohio law is, it is our >>> assessment that it likely prohibits providing any compensation for a >>> referral if the client is paying by long-term care insurance. The safe >>> route is to exclude them from potential referrals. >>> >>> Happy to jump on a call to discuss further if needed. >>> >>> >>> >>> On Mon, Jan 27, 2025 at 9:51=E2=80=AFAM Will Reid wr= ote: >>> >>>> Steve, >>>> Do you have an update? >>>> >>>> Thanks >>>> >>>> >>>> Will Reid >>>> Partner >>>> * Please note my email has changed: * >>>> wreid@thekey.com >>>> 513-707-2304 >>>> TheKey.com >>>> [image: TheKey] >>>> >>>> >>>> On Thu, Jan 16, 2025 at 12:42=E2=80=AFPM Steve Koyanagi >>>> wrote: >>>> >>>>> I'll leverage some resources to see if we can get a more definitive >>>>> answer. I'll be in touch when we know more. >>>>> >>>>> On Thu, Jan 16, 2025 at 9:38=E2=80=AFAM Will Reid = wrote: >>>>> >>>>>> I'd prefer to keep LTCi clients in the agreement. Is it possible to >>>>>> get a definitive answer? If not we should exclude it. I don't want t= o put >>>>>> an Ambassador at risk. >>>>>> >>>>>> Thanks, >>>>>> >>>>>> Will Reid >>>>>> Partner >>>>>> * Please note my email has changed: * >>>>>> wreid@thekey.com >>>>>> 513-707-2304 >>>>>> TheKey.com >>>>>> [image: TheKey] >>>>>> >>>>>> >>>>>> On Thu, Jan 16, 2025 at 12:27=E2=80=AFPM Steve Koyanagi >>>>>> wrote: >>>>>> >>>>>>> Hi Will, >>>>>>> >>>>>>> One other flag. Given the Company is looking to expand referral >>>>>>> networks and preferred provider arrangements in 2025 we've been doi= ng some >>>>>>> additional legal research in this area. There is potentially some r= isk in >>>>>>> Ohio if a referred client is using long-term care insurance as ther= e is an >>>>>>> Ohio criminal law that prohibits paying a referral fee is the servi= ces >>>>>>> are reimbursed by a "health care plan." (See Ohio Rev. Code Ann. = =C2=A7 >>>>>>> 3999.22(B) (creating criminal liability for offering/receiving any >>>>>>> remuneration for referral of goods/services reimbursable by any hea= lth care >>>>>>> plan). Certainly, we can argue that long-term care insurance is not= a >>>>>>> "health care plan," but this is a gray area. >>>>>>> >>>>>