--000000000000f8a2a9062cb4dee2 Content-Type: multipart/alternative; boundary="000000000000f8a2a8062cb4dee0" --000000000000f8a2a8062cb4dee0 Content-Type: text/plain; charset="UTF-8" Content-Transfer-Encoding: quoted-printable 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 wrote= : > 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 wro= te: >> >>> 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 w= rote: >>>> >>>>> 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 to= 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 doin= g some >>>>>> additional legal research in this area. There is potentially some ri= sk in >>>>>> Ohio if a referred client is using long-term care insurance as there= is an >>>>>> Ohio criminal law that prohibits paying a referral fee is the servic= es >>>>>> 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 heal= th care >>>>>> plan). Certainly, we can argue that long-term care insurance is not = a >>>>>> "health care plan," but this is a gray area. >>>>>> >>>>>> Would you have an issue excluding LTC clients from the brand >>>>>> ambassador program or is this a significant revenue source? >>>>>> >>>>>> Let me know your thoughts and/or if yo