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election, ranging from $380 to $645 per year (with such amounts subject to Consumer Price Index

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increases). This translates into an RHI surcharge of $9,000 to $16,125 (or more) over the life of the 25

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year timeshare lease. For a $5,000 purchaser, this would ultimately equate to a total payment of at least

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$14,000 in return for 12 weeks of timeshare access (over a 25 year period) at an undisclosed location

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during an undisclosed time of year.

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20. Under YUCATAN’s alleged “Option 1,” investors can purportedly choose to forego any

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returns on their investments, and instead chose to utilize a timeshare unit themselves. Under this option,

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RHI assigns to the investor, at RHI’s own choosing, a specific unit, for a specific week,1 and at a specific

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location, and only after the $5,000 sum (or more) is received by RHI. The investor has no input into the

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23. YUCATAN’s Universal Lease “Option 2,” which ostensibly allows YUCATAN customers to

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rent out assigned timeshare units themselves, contains many of the same prohibitive costs and conditions

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as that of Option 1. This Option again requires the purchaser to forego any guaranteed investment

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returns, and instead imposes substantial annual maintenance fees on the purchaser for the full 25 year

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lease term. Prospective Option 2 purchasers must also await a determination by RHI, after the purchase

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19. Evidencing this point, recruiters for prospective YUCATAN sales agents coach their trainees

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that the Universal Lease’s “third option,” i.e. the investment selection, is the only selection that need be

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promoted, offered and sold.

Docket No. S-03539A-03-0000

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YUCATAN promotional materials, and the selection receives no coverage in the YUCATAN

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recruitment seminar for prospective salesmen. Equally relevant, this option would simply have no

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applicability to the many investors rolling retirement funds into the YUCATAN program.

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date, quality or location of this timeshare assignment.

21. Moreover, the Option 1 purchaser must pay annual management fees to RHI for this particular

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22. Consistent with these uninviting terms, this vacationing selection is largely ignored in

1 According to the promotional materials, a $5,000 YUCATAN investor electing the purported “option 1” receives access to the assigned timeshare unit only every other year, or only 12 to 13 weeks during the 25 year lease period.

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