This is bizarre ... and anachronistic: Like something out of a 21st century Jane Austen novel. My view of this and similar things (both by US and other organizations) is that this is what happens when rules are down-sourced to lower levels and no one in charge is thinking about the bigger picture. I mean, the same people (CPs, in general) who get this (nice) Special Dividend -- but who can't seem to get it unless they are leading a Jane-Austen-like existence -- are allowed to hold award seats without penalty for wives / mistresses / lovers / strangers / husbands ... whoever!
Okay, this said, I think that the Special Dividends are comparatively new and they have not yet worked out the kinks. So I would keep sending letters and e-mails (polite, of course) up and down the line until they reach someone who is thinking. As I have noted elsewhere, they have been able to fix some of the original illogic in the implementation of other parts of the Special Dividends, for example, the duration of the first-class award upgrade benefit, and the on-line system for granting status to others.