[antonej]

FWIW, I've personally worked with partners at a couple of these funds, as well as some of the senior execs at the parent company, and they are stand-up guys, not con artists. Aggressive direct marketing isn't a crime (have you ever watched TV infomercials?), although there are certainly gray areas where disclosure could be clearer, etc.

IMHO the most important consideration is that the more aggressive any company is about acquiring new customers under this kind of model, the more liberal it should be about returns/refunds/cancellations. There were many lessons learned a couple years ago when discount-membership checkout programs (WebLoyalty, Affinion, Vertrue) and their e-commerce partners (Fandango) got the smackdown from various state AGs. There's enough similarity here to warrant paying close attention and making sure to stay on the right side of a thin line. Here's example coverage of the previous controversy:

http://www.zippycart.com/ecommerce-news/1165-affinion-vertru...