About Inspirato

Inspirato LLC (“Inspirato”) is a luxury hospitality subscription company that manages and operates an inventory of luxury vacation homes, hotels, properties and experiences (the “Inspirato Collection”).  Individuals who purchase certain passes or memberships through Inspirato (“Inspirato Members”) have exclusive access to properties and travel experiences through the Inspirato Collection.  Inspirato is not a real estate broker and does not represent potential buyers or sellers in any real estate transaction.

 

The Purchase-and-Lease Program

This information statement (“Information Statement”) is intended to provide important information about Inspirato’s Real Estate Purchase-and-Lease Program (the “Purchase-and-Lease Program”). It does not constitute an offer to sell or a solicitation of an offer to buy any interests in Inspirato or its Purchase and Lease Program or any other securities. The information provided in this overview is not and should not be considered a recommendation to purchase or sell any particular interest or security.

Inspirato has created the Purchase-and-Lease Program to offer multi-year term leasing arrangements (a “Lease Agreement”) to owners of newly acquired real estate, typically involving single family luxury properties located in certain destination areas in the United States (a “Property”).  Through the Purchase-and-Lease Program, Inspirato and Property owners (“Participating Owners”) will enter into a negotiated Lease Agreement under which Inspirato will (i) generally make an upfront capital investment in the Property; (ii) be the exclusive lessee of the Property (for the benefit of Inspirato Members to occupy and use in accordance with Inspirato’s membership plans); and (iii) serve as the exclusive property management service provider.  Participating Owners should consider their participation in the Purchase-and-Lease Program as making an investment in a Property that will be leased to Inspirato for a fixed period of time. The viability of the Purchase-and-Lease Program is dependent on the overall success of Inspirato.

The following provides a description of the Purchase-and-Lease Program including typical lease terms and other information that prospective Participating Owners should know prior to entering into a Lease Agreement and, where applicable, deciding to purchase a Property with the intention of participating in the Purchase-and-Lease Program.

 

Important Considerations

Prospective Participating Owners must rely on their own assessment and evaluation of purchasing a Property with the intention of participating in the Purchase-and-Lease Program, including the overall merits and risks involved in purchasing and owning investment vacation properties.  Ownership of investment vacation properties presents unique financial risks some of which are described below.  No assurance can be made that Participating Owners will achieve any particular financial returns under the Purchase-and-Lease Program or otherwise from the Property.  Such an undertaking should therefore be considered only by sophisticated individuals who can bear the economic risks of such ownership.  See below under “Certain Risk Factors” for a description of some of these considerations.

Prospective Participating Owners EXPRESSLY ACKNOWLEDGE THAT WITH RESPECT TO ESTIMATES, FORECASTS AND PROJECTIONS PROVIDED IN CONNECTION WITH PROPERIES THAT MAY PARTICIPATE IN THE Purchase-and-Lease Program, (i) NO ASSURANCE CAN BE GIVEN REGARDING THE ACCURACY OR APPROPRIATENESS OF THE ASSUMPTIONS AND JUDGMENTS MADE, OR THE METHODOLOGIES USED AND SUCH ESTIMATES, FORECASTS AND PROJECTIONS ARE FORWARD-LOOKING STATEMENTS AND INVOLVE RISKS AND UNCERTAINTIES THAT MAY CAUSE ACTUAL RESULTS TO BE MATERIALLY DIFFERENT FROM THE ESTIMATES, FORECASTS AND PROJECTIONS. ACCORDINGLY, ANY PROSPECTIVE PARTICIPATING OWNER SHOULD RELY ON SUCH ESTIMATES, FORECASTS AND PROJECTIONS AT ITS OWN RISK.

Where Inspirato refers prospective Participating Owners interested in purchasing a Property to certain real estate brokers, Inspirato may receive a referral fee if the Prospective Participating Owner purchases a Property. Importantly, any referral fee paid to Inspirato by a real estate broker will be paid from the total fee or real estate brokerage commission paid to a real estate broker in connection with the purchase of a Property and will not increase the fees or real estate brokerage commissions paid by Prospective Participating Owners. The terms of any referral fee may also be included in a Lease Agreement between Inspirato and a Participating Owner.

Prospective Participating Owners are invited to ask questions of, and obtain additional information from, Inspirato regarding the Purchase-and-Lease Program.  A prospective Participating Owner should not participate in the Purchase-and-Lease Program unless satisfied that they have received all information that would enable them to evaluate whether or not they should be based upon their own financial circumstances and objectives.

Summary of Lease Agreement Terms

Each Lease Agreement will be specifically negotiated with Participating Owners.  The following summarizes customary key provisions of Lease Agreements.  This summary is subject to, and qualified in its entirety by, the actual terms of the Lease Agreement entered into by Inspirato and a Participating Owner.  The Lease Agreement and documents referred to therein, and the Participation Eligibility Questionnaire attached as Schedule A (together, the “Program Documents”) should be reviewed carefully prior to deciding to purchase a Property with the intention of participating in the Purchase-and-Lease Program:

  1. Service Inspirato or its Third-Party Contractors Will Provide.  Inspirato, at its expense, or through third-party contractors provides services such as concierge services, housekeeping and laundry services and other amenities as described in a Lease Agreement.
  2. Expenses Inspirato Will Cover.  Generally, Inspirato will pay costs and expenses relating to the following: customary utilities and landscaping maintenance expenses; routine repairs and maintenance; liability and property insurance; agreed-to capital expenditures, if applicable; repair of certain damages caused by Inspirato Members whose use the Property; lodging and/or short-term occupancy taxes and taxes on the personal property of Inspirato located at the Property; operating supplies and equipment such as bedding, linen, household goods and supplies including small appliances (“OS&E”); and, subject to any Property Improvement Budget and capital improvements identified below under “Expenses Participating Owners Will Cover,” furniture, fixtures, and equipment (“FF&E”) including audiovisual equipment (“A/V”) identified as necessary or desirable.  Unless a Lease Agreement provides otherwise, Inspirato will have the right to remove all OS&E, FF&E and AV upon the termination of the Lease Agreement.
  3. Expenses Participating Owner Will Cover.  Participating Owners, at their own expense, are responsible for any items for which Inspirato has not specifically assumed responsibility under the Lease Agreement including the following: repairs and improvements agreed to be made by the Participating Owner pursuant to a pre-lease inspection of the Property; repair of damages not included in the damages which Inspirato has agreed to repair; real estate taxes and taxes on the personal property of the Participating Owners located at the Property; landlord property and liability insurance; HOA dues and association assessments; OS&E, FF&E and AV pursuant to a “Property Improvement Budget” agreed to with Inspirato before the Lease Agreement is signed; capital repairs (such as replacement of the roof) and maintenance other than those for which Inspirato has specifically agreed to be responsible.
  4. Participating Owner Usage.  During the term of a Lease Agreement, all initiation fees and annual renewal fees for Inspirato Members will be waived for the Participating Owner and the Participating Owner will, subject to its agreement to Inspirato’s Standard Terms and Conditions, have unlimited access to Inspirato’s portfolio of Inspirato Residences, Experiences and Hotel Rooms & Suites, subject to the standard member nightly rate.
  5. Term; Early Termination Rights.  The term of a Lease Agreement is typically 5 years with extension rights as may be provided in a particular Lease Agreement.  Each Lease Agreement will identify the conditions that can trigger termination of the lease and the parties’ obligations in the event of termination.  Importantly, Inspirato can generally terminate the Lease Agreement in the event the quality of the Property (except for elements not in Inspirato’s control) materially diminishes following Inspirato’s occupancy date, provided that Inspirato provides the Participating Owner with 180 days written notice thereof.  Inspirato and Participating Owner each will also have the right to terminate the Lease Agreement upon certain defaults thereunder by the other party, as outlined in the Lease Agreement. 
  6. Assignability.  Inspirato has the right to assign its rights under the Lease Agreement without the Participating Owner’s consent in connection with (i) any transfer to an affiliate or subsidiary of Inspirato; (ii) any restructuring of Inspirato or its affiliates; or (iii) an acquisition of all or substantially all of Inspirato’s or its affiliates assets or equity.  Participating Owners have the right to assign the Lease Agreement to purchasers of all of the Participating Owner’s interest in the Property or the Participating Owner’s right to operate the Property, in each case with Inspirato’s prior written consent which will not be unreasonably withheld, so long as the assignee is not a competitor of Inspirato and the assignee assumes all of the Participating Owner’s liabilities under the Lease Agreement.
  7. Indemnification by Inspirato.  Inspirato will indemnify the Participating Owner against damages and claims relating to (i) negligent acts or willful misconduct by Inspirato or its agents, guests or Inspirato Members and (ii) damages and claims by Inspirato’s guests or Inspirato Members resulting from any injury or death occurring on the Property except where caused by the Participating Owner’s (or its agents’ or invitees’) negligent acts or omissions.
  8. Indemnification by the Participating Owner.  The Participating Owner will indemnify Inspirato (and its guests, Inspirato Members, agents, and affiliates) against damages and claims relating to the Participating Owner’s breach of the Lease Agreement or the negligent acts, misconduct, or omissions by the Participating Owner or its agents and invitees.
  9. Lease Disputes.  Any Lease Agreement disputes between Inspirato and the Participating Owner must be resolved in accordance with the terms in the Lease Agreement.  

The terms summarized above should not be viewed as a comprehensive or accurate description of all material provisions of the Lease Agreement between a Participating Owner and Inspirato.  Any of these provisions are subject to change in the Lease Agreement actually entered into.  Prospective Participating Owners should therefore carefully review the Lease Agreement prior to signing it and seek advice of its own legal, financial and/or tax advisers prior to doing so.

Summary of Property Management Terms

As per the terms of the Lease Agreement between a Participating Owner and Inspirato, Inspirato will serve as the exclusive manager of a Participating Owner’s Property in the Purchase-and-Lease Program. Participating Owners understand and unconditionally agree that Participating Owners will have no right to utilize a property management company for a Property in the Purchase-and-Lease Program other than Inspirato during the term of any Lease Agreement.

Lease Agreements will identify Inspirato’s responsibilities for managing a Participating Owner’s Property.

Inspirato will exercise due diligence and make reasonable efforts to protect the Participating Owner’s Property. Inspirato will use reasonable efforts to manage the property with regard for the rights, safety, and health of those lawfully on the premises.

Participating Owners are expected to cooperate fully with Inspirato for matters that are related to Inspirato’s ability to manage the Property.

Participating Owners who elect to sell a Property during a Lease Term agree to notify any prospective purchaser of the Property of the nature of the Lease Agreement and Inspirato’s exclusive service as the exclusive property management company during the term of the Lease Agreement.

 

Certain Risks to Consider

The purchase of a Property and participation in the Purchase-and-Lease Program should be undertaken only by sophisticated persons as such activity could result in financial loss.  Prospective Participating Owners should carefully consider the following and consult their own legal, tax and/or financial advisers with respect to such matters.  The following summary is not meant to be an exhaustive listing of all potential considerations associated with the purchase of a Property and participation in the Purchase-and-Lease Program and does not imply that there are no other substantial risks.

  1. Risks Related to the Lease Agreements.

Leasing a Property to Inspirato pursuant to the Purchase-and-Lease Program presents certain risks to consider, including the following:

  • The Lease Agreements will be subject to early termination, which can be disruptive and costly.
  • The initial term of the Lease Agreement is a longer term, typically 5 years. While providing certainty of lease income for that period versus a shorter-term lease, a longer-term lease also presents risks including that the lease payments may be or in the future become lower than rates that could be obtained from other tenants.  Participating Owners are unable to terminate the Lease Agreement prior to the end of its term and can typically only do so under limited circumstances related to Inspirato’s breach of the Lease Agreement.  Accordingly, a Participating Owner may receive below-market lease payments for a significant period of time.
  • If Inspirato breaches a Lease Agreement by failing to make lease payments or pay other costs and expenses under the Lease Agreement, a Participating Owner could experience delays in enforcing its rights as a landlord and may incur substantial costs in protecting its investment in the Property, including fees for engaging an attorney.
  • In most Lease Agreements, Participating Owners will be materially restricted in their occupancy of their Property, and they will not be able to select property management service providers other than Inspirato.
  • Inspirato’s ability to perform its obligations under a Lease Agreement could be materially impacted if its business operations suffer losses or are otherwise impaired.
  • Inspirato and its guests, Inspirato Members and agents at a Property are entitled to indemnification from the Participating Owner for certain claims and damages which could in some cases result in a material adverse financial impact on the Participating Owner.
  • Disputes under the Lease Agreement may be litigated in a geographical location that is not near the Property and can be costly to Participating Owners.
  • Participating Owners may transfer their rights, duties and obligations under a Lease Agreement in a single transaction to an individual or entity that acquires all of: (i) Participating Owner’s full ownership interest in the Property; or (ii) Participating Owner’s right to operate the Property, each with Inspirato’s prior written consent, which will not be unreasonably withheld, provided that such assignee is not (A) a competitor of Inspirato or any of its affiliates, and (B) assumes the Lease Agreement and all of the Lease Agreement’s obligations and liabilities. There can be no assurance that purchasers of Properties will be willing to assume such obligations which could make it more difficult to sell a Property when a Participating Owner may have need for liquidity.
  • In the event of a Force Majeure (as this term is defined in the Lease Agreement), Inspirato and Participating Owner’s obligations and the time periods for the performance of such obligations (including Inspirato’s payment of Rent to Participating Owner) shall be adjusted to the extent and for the amount of time Inspirato is prevented, hindered, or delayed in its ability to use or provide access to the Property to Inspirato Members during the period of such Force Majeure. Inspirato will recommence the operation of the Property when Inspirato reasonably determines that the period of Force Majeure has ended. If at any time during the Term of a Lease Agreement, the Property shall be totally or partially destroyed, unusable, or unrentable as a result of a Force Majeure, Inspirato shall have the option, within 30 days of assessing the Force Majeure event, to terminate the Lease Agreement without further liability. If the Property requires repair as a result of a Force Majeure, the Rent shall be abated to the extent that the Property, or any portion thereof, shall have been rendered untenantable, such abatement to be from the date of such damage or destruction to the date the Participating Owner’s repair obligations have been completed.
  • To the extent that a Participating Owner has a right to provide Inspirato and/or Inspirato Members with access to amenities appurtenant to the Property, at no additional cost to Inspirato, and throughout the Term of a Lease Agreement, Inspirato Members will have access to those amenities at the same level of service and access as a Participating Owner. If at any time during the Term of a Lease Agreement, Inspirato and Inspirato Members are denied access to operating amenities not as a result of general closure of such amenities, these circumstances shall be considered a Participating Owner’s breach of the Lease Agreement, which if not cure within 10 business days of receiving notice of the breach, will give Inspirato the right to terminate the Lease Agreement.
  1. Risk Related to Investment Property Ownership.

Independent of the Purchase-and-Lease Program, investing in vacation investment properties presents unique risks that should be considered independently of leasing such properties to Inspirato:

  • Vacation properties can experience significant variations in demand depending upon their location, type of property and competitive alternatives. Following termination of the Lease Agreement, a Participating Owner’s ability to lease a Property (at all or at attractive rates), or to sell a Property, can be negatively impacted by a number of factors such as the competitive landscape of local markets; excessive building resulting in an oversupply of similar properties in the area; deterioration of surrounding areas; deterioration, closure or limits on use of community amenities; national or local economic, political, public health and other conditions; a decrease in market rates; a lack of perceived safety, convenience and attractiveness; changes in weather patterns that can adversely affect certain areas; changes in travel service availability and convenience of accessing certain locations such as the reduction or elimination of airline services.
  • A Property will be subject to general real estate risks attendant to any residential property purchased for the purpose of leasing it to third parties. These include fluctuations in rents, occupancy rates and operating expenses as described in these Certain Risk Factors, adverse changes in real estate zoning laws, land use regulations, laws and regulations concerning short-term rental of residential property, environmental issues including discovery of unsafe conditions on the property or adjacent or nearby properties, acts of God and other factors that are beyond the control of property owners, failure of tenants to pay rent, vandalism, adverse use of adjacent or neighboring real estate, over-supply of competing residential properties, ongoing need for capital improvements, and increased real property taxes.  Because certain costs of real estate ownership (principally real estate taxes, debt payments, and insurance) do not generally decrease with decreases in occupancy rates, the cost of operating a Property may exceed the income the Property generates.
  • A Property may incur vacancies either by the continued default of a tenant under its lease, the expiration of a lease or early termination of a lease by a tenant. Vacancies result in less income to the Property Owner and could cause owners to be unable to meet any mortgage obligation secured by the Property, potentially resulting in a foreclose by the mortgage holder. 
  • There can be no assurance that a Property will operate at a profit, will appreciate in value or will be sold at a profit. The marketability and value of a Property will depend upon many factors beyond the control of the Property owner.  There also can be no assurance that there will be a market for resale of the Property.  Market conditions existing at the time of the desired sale of a Property could make the financing or the sale to prospective purchasers difficult or costly to obtain financing and, therefore, reduce the ability of the owner to sell the Property for an acceptable price.
  • Increases in interest rates or decreases in the availability of loans to potential purchasers of a Property may render sales of the Property difficult or unattractive.
  • Increases in real estate (or real property) tax rates, maintenance costs, utility costs and other operating expenses could adversely affect a Property Owner’s returns on investments in Properties.
  • Structural or other defects or damage, including as a result of tenant vandalism, or failure of a tenants to adequately maintain the Property, could occur or be found on a Property resulting in adverse economic impacts to the owner.
  • Natural disasters that might not be covered by insurance, such as earthquakes, hurricanes, fires and floods could cause a complete loss on an investment in a Property.
  • The reduction or elimination in access to certain amenities appurtenant to a Property may cause the value of a Property to decline significantly or make it a less desirable rental property.
  1. Risks Related to Exclusive Property Management Services
  • As mentioned above, Inspirato will be solely responsible for providing property management services for a Property in the Purchase-and-Lease Program. If this were not a condition of the Lease Agreement, Participating Owners might be able to pay less for property management services and obtain more comprehensive services for lesser costs than Inspirato offers.
  • Inspirato uses third-party contractors to perform most, if not all, of the property management services for Properties in the Purchase-and-Lease Program. Third-party contractors can cause damage to a Property. Inspirato and Participating Owners agree that any third-party contractors that perform any of Property Owner or Inspirato’s obligations under a Lease Agreement shall have commercial general liability insurance with minimum limits of $1,000,000.00 per occurrence and $2,000,000 in the aggregate, and such third-party contractor’s insurance shall provide primary insurance coverage in the event of any loss or claim and will include Inspirato and Participating Owner as additional insureds.

 

Eligibility Requirements

When Inspirato promotes the economic benefits of its Purchase-and-Lease Program to prospective Participating Owners, such arrangements could constitute investment contracts under federal or state securities laws.  Prospective Participating Owners should be aware that the Purchase-and-Lease Program may be considered a private securities offering and has not been and will not be registered under the Securities Act of 1933, as amended (the “Securities Act”), or any other securities law, because the offering of such participation rights will be exempt from registration pursuant to Rule 506(c) of Regulation D of the Securities Act and only available to prospective Participating Owners who satisfy certain eligibility requirements described below.  No public or other market will develop for the interests.

Participating Owners must be US persons that qualify as “accredited investors” as defined in Regulation D under the Securities Act of 1933, and a Property in the Purchase-and-Lease Program must be in the United States. Accredited investors are able to appropriately evaluate the risks and merits of participating in the Purchase-and-Lease Program and to withstand the loss of all or a substantial portion of their investments in a Property through their participation in the Purchase-and-Lease Program.  Participating Owners must complete a Participation Eligibility Questionnaire in the form of Schedule A attached to this Information Statement.  The satisfaction of these standards does not necessarily mean that participation in the Purchase-and-Lease Program are a suitable investment for a Participating Owner.  Participation in the Purchase-and-Lease Program is not intended as a complete investment program but should be viewed as one component in the development of a balanced allocation of investment capital.

Neither the U.S. Securities and Exchange Commission nor any state securities commission has approved or disapproved of the Purchase-and-Lease Program described in this Information Statement or passed upon the adequacy or accuracy of the information provided.  Any representation to the contrary is a criminal offense.  In addition, this Information Statement does not constitute an offer or solicitation to prospective Participating Owners in any state or other jurisdiction in which an offer or solicitation is not authorized.

SPECIAL NOTICE TO FLORIDA RESIDENTS:  The Purchase-and-Lease Program has not been registered under the Florida Securities and Investor Protection Act (the “Florida Act”).  Each prospective Participating Owner who is a Florida resident should be aware that Section 517.061(11)(a)(5) of the Florida Act provides, in relevant part, as follows: “When sales are made to five or more persons in this state, any sale in this state made pursuant to this subsection is voidable by the purchaser in such sale either within 3 days after the first tender of consideration is made by such purchaser to the issuer, an agent of the issuer, or an escrow agent or within 3 days after the availability of that privilege is communicated to such purchaser, whichever occurs later.” To accomplish this, a Participating Owner need only send a letter or telegram to Inspirato at the address shown herein within such three (3) day period, stating that he or she is voiding and rescinding the Lease Agreement.  If any Participating Owner sends a letter, he or she should do so by certified mail, return receipt requested, to ensure that the letter is received and to evidence the time of mailing.  The availability of the privilege to void sales pursuant to Section 517.061 of the Florida Act is hereby communicated to each Florida offeree.

Availability of Additional Information

In making a decision about whether to participate in the Purchase-and-Lease Program, prospective Participating Owners should rely only on the information contained in this Information Statement and the other Program Documents.  Inspirato has not authorized anyone to provide information different from that contained in the Program Documents.  Each prospective Participating Owner should disregard any other information it has received from any other source, orally or in writing.  Inspirato will make available to each potential Participating Owner and such Participating Owner’s legal, tax and financial advisors, if any, the opportunity to ask questions and receive answers concerning the terms and conditions of the Purchase-and-Lease Program.

 

 Additional Terms Applicable to Services Provided by Inspirato

If you have been granted access to certain non-public portions of Inspirato’s website (the “website”) through a uniquely assigned Investor log-in or by acknowledging you meet certain criteria to evaluate the Purchase-and-Lease Program (“Investor Sections”) as either someone who desires to become a Participating Owner or a representative of a Participating Owner, your use of the Investor Sections may also be governed by applicable other agreements and by all applicable laws and regulations. All information available through the Investor Sections of the website is confidential and proprietary to Inspirato. This includes all investment-related information, estimations, and results, offering materials, financial statements and other information provided through the Investor Sections of the website. You will use best efforts to keep all this information strictly confidential. You will not disclose any of this information to any person or use it for any purpose other than those expressly permitted by Inspirato in writing.

If you have been granted access to the Investor Sections by Inspirato, you must maintain confidentiality of your log-in information and you remain responsible for all usage of the Investor Sections of the website through your account, whether such use is made by you or anyone else. You must immediately notify Inspirato of any known or suspected unauthorized use of your log-in information or any known or suspected breach of security, including loss, theft or unauthorized disclosure of your log-in information. You acknowledge and agree that the content on the website, including the Investor Sections, is solely for general, informational purposes and nothing contained in the Site may be construed as a recommendation or representation of suitability or endorsement of any security or investment and any information generally contained on the website and not contained in the Investor Sections may not be relied upon in connection with any offer or sale of securities or other assets.

Offering materials regarding the Purchase-and-Lease Program are approved only by Inspirato. Inspirato is not providing the Investor Sections of the website to provide investment or other advice, and nothing herein should be deemed to be a recommendation that you buy, sell, or hold any security or other investment. You further acknowledge and agree that the content on the website does not provide any tax, legal, accounting or other professional advice.

In making an investment decision, potential Participating Owners must rely on their own examination of a Property and an investment, including the merits and risks involved. Before making any investment, an investor should thoroughly review the confidential offering documents with the investor’s financial, legal and/or tax advisor to determine whether an investment is suitable for the investor in light of the investor’s investment objectives, financial circumstances and tax situation. The information contained on, or comments expressed on, the website may include certain prior indications of past investment performance. In considering such prior performance information, prospective Participating Owners should bear in mind that past performance is not necessarily indicative of future results and there can be no assurance that an investment will, or is likely to, achieve comparable results to those achieved in the past, or that significant losses will be avoided.

Market analyses and statements of opinions provided on the website are inherently uncertain and are based on a number of assumptions. Prospective Participating Owners should carefully review information regarding any such analyses and underlying assumptions.

Certain information on the website may contain certain “forward-looking statements” about Inspirato which can be identified by the use of words such as “may”, “will”, should”, “expect”, “anticipate”, “project”, “estimate”, “intend”, “continue”, or “believe” or similar expressions. Inspirato undertakes no obligation to update publicly or revise any forward-looking statements. Due to various risks and uncertainties, actual events, results, or performance may differ materially from those reflected or contemplated in such forward-looking statements. No representation or warranty is made as to future performance or such forward-looking statement.

For additional Legal Notices and Disclaimers, please visit: https://www.inspiratorealestate.com/footer-pages/legal

 

SCHEDULE A

PARTICIPATION ELIGIBILITY QUESTIONNAIRE