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Just as a few others mentioned, I also had a 25 day statement and was fine for the 91/3.
Hope you have some great news soon!
In our experience, it wasn't only about the number of days the statement was cut since receiving an approval on a Navy CC app. I think the real hint to look for is actually the Minimum Payment Due on that 1st statement. If it is a short statement and it shows a $0 MPD, then I believe you should wait for a 4th statement. If that MPD is any amount other than $0, then I think that 1st statement counts as a "full" statement even if it doesn't include 28+ days.
My two DD's and DW each have two CC's with Navy. Typically, we would use the card the day it arrived to verify everything was good. With that practice, the first statement ALWAYS posted a MINIMUM PAYMENT DUE other than $0... even if the statement cut early at 14 days since application. All 6 CC's were able to get a CLI around 91-100 days and only 3 statements (including several statements with less than 20 days since application approval) and they were approved for their 2nd Navy CC's.
For my Navy CC that I got a few months ago, I didn't put any spend on it immediately. I had an early statement cut, and it had no minimum payment due on that first statement. I will definitely wait on my 4th statement (aka 3 "full" statements) before applying for my 2nd card or CLI.
This is just my theory and it needs more DP's to be confirmed. I wish I had put some spend on my card immediatly, then I could have tested the theory with a CLI request this month.
Thank you everyone for the responses. It seems the consensus is that my 28 day first statement counts as full, so I think I will try it after the third statement hits and we shall see how it goes. I have ~two weeks left, so I will update this with the outcome then!
Updating since I said I would:
I did not end up applying for a second card, due to a change in personal circumstances/plans. However, I did still go for the CLI. My 3rd statement would've cut Aug 24th and my 91 days would've been Aug 26/27th. I waited until after the weekend and requested the CLI on Aug 31st. Less than 24 hours later it was approved and reflecting in my available credit. So, it appears that, yes, my first statement did in fact count as a full one.
Thanks everyone!
As the OP has provided an update on their successful CLI, this thread is now locked and closed to new messages. Nice job with the CLI, OP!