N.Y. Comp. Codes R. & Regs. tit. 2, § 150.3
(a) On or before December 15, 1995, or within 30 days after the adoption of a service award program, whichever is later, the chief executive officer of the sponsor shall file with the Office of the State Comptroller in Albany, NY, two copies of a verified notice of adoption which shall contain the following:
(3) an opinion of legal counsel which shall: