I'll bet my lease on the London Bridge that it's a silver Ugnaught.
All kidding aside, this has disaster written all over it, as the rest of you have already said. Did the Fan Club (of which I am aware this is not technically an offshoot of as in the past) ever have an exclusive Hasbro figure that wasn't a complete pain to get ahold of?
For the record, here is the list of the non-silver exclusive figures over the POTF2/POTJ/E1/Saga era (not counting the Animated Clone Wars figures):
-Mace Windu (1998; Hasbro mail away)
-Muftak and Kabe (1998; Hasbro internet)
-Oola and Salacious Crumb (1998; Fan Club)
-B'Omarr Monk (1997; Hasbro internet)
-Spirit of Obi-Wan Kenobi (1997; Lays mail away)
-Cantina Band Member (1997; Fan Club)
-Han Solo in Stormtrooper Disguise (1995; Froot Loops mailaway)
Did I leave anyone out? So, as you said, Mr. Bryant
the last non-silver exclusive figure was Mace Windu from the end of the 1998 line. It's been almost six years since then. Apparently it's not as cost-prohibitive to do a newly sculpted figure as a premium after all; it just has to be done when it benefits you, and with all the bad collector karma from the OTC disaster in the making, Hasbro needs all the benefits it can get.