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September 06, 2011


Carol H

Isn't there a difference in the time frame between the two opinions? The 1993 letter is responding to an inquiry based on an annual award; the current Legal Opinion Letter provides for such an award "at the end of each five-year period".

Steve Van Beek

Yes - the 2011 does look a 5-year award whereas the 1993 letter looks at an annual award. I think NCUA's opinions are still consistent - but are just limited to the question asked. In the 2011 opinion, NCUA does break the $250 gift card into nominal annual terms ($50 per year) which coincides with the timeframe in the 1993 letter.

If you had an annual award, you should be able to rely on both the 1993 and the 2011 letters for support.

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