Virgin Australia has been ranked amongst the top six airlines of global carriers when it comes to the availability of frequent flyer reward seats based on the sixth annual Switchfly Reward Seat Availability Survey, which attempts to book award redemptions on carriers. The survey looks at 280 paired city flights, giving each airline a percentage for the time reward seats are successfully booked, then assigning points up or down to show where the airlines have moved on the table since last year. Virgin’s Velocity program, which has 3.5 million members, was ranked second with a score of 96.4 per cent, reflecting the fact that 270 of 280 outbound and inbound date queries provided a minimum of one flight in each direction with at least two available reward seats. Qantas, with 9.1 million Frequent Flyer members, was ranked ninth with a score of 72.9 per cent, down 3.5 points on last year.

Required
Assume that the 3.5 million Virgin Velocity members had an average of 200000 frequent flyer points. Referring to the Conceptual Framework, discuss if Virgin Australia has a liability to record in relation to its frequent flyer program.