Our client is a national banking program that has purchased REC's as a corporation in 2010 and 2011 as part of a corporate portfolio program. They have provided the appropriate documentation of contracts, purchase price and power amounts. We have allocated the RECs to cover 100% of annual power usage to our separate LEED Projects (currently 5 different locations). Question #1- Can we allocate the REC’s from 2010/2011 until all of the purchased units are allocated to LEED projects, even though the buildings won’t open until 2012? Is there an expiration of how long REC’s are applicable from a given year? Question #2 – What is the best way to document that we are not “double dipping” on allocating the power to different sites? The GBCI has made comments but will not give any additional information on how they determine the documentation is appropriate. Question #3 – Does the bank need to purchase a new portfolio of REC’s for 2012 for new LEED projects starting in 2012?