This opinion, requested by the Colorado Commission on Higher Education (“CCHE”), concerns the The 2004 College Opportunity Fund Act, § 23-18-101 et seq. (the “Act”). The Act created the College Opportunity Fund; a trust fund consisting of stipends for each undergraduate student in Colorado. This Opinion is being issued to clarify how the College Opportunity Fund affects calculation of federal financial aid, and the effect, if any, that such calculations have on whether such stipend should be considered a state grant for purposes of Colo. Const. Art. X, § 20 ( “TABOR”).