CRC builds the application infrastructure. – Cannabis & Hemp


United States: CRC builds the application infrastructure.

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As discussed in detail during Foley Hoag’s recent New Jersey webinar, the adult use regulations issued by the New Jersey Cannabis Regulatory Commission (“CRC”) contain several unanswered questions. For example, when will CRC start accepting applications (they have already passed the legal deadline)? How will applicants navigate the complexity of the local municipal approval process amid opt-in and opt-out cities? How important are the different entities and types of licenses described in the regulations and the priority, preference and incentives associated with each?

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The good news is that the CRC has apparently recognized that the 160+ pages of regulations do not necessarily speak for themselves and, as such, has scheduled an educational meeting on September 28, 2021 (“Reunion”) in the hope. to provide additional clarity. Specifically, the topics that will be discussed during the meeting will include:

  • Explanation of the initial rules:
    • Equity provisions.
    • Security arrangements.
    • General guidelines for municipalities.
    • Overview of available licenses.
  • Basic application requirements (including focus on the differences between conditional and annual licenses and reference to the notice of acceptance of the upcoming application), including:
    • Overview of social equity enterprises, enterprises with diversified holdings, enterprises of the impact zone.
    • Monitoring changes in municipal approaches.
  • What businesses can do to prepare to apply (e.g. business registration, DOB certifications).
  • Expectations for CRC Background Investigations.
  • Management services contracts and FSA 101 and protections and red flags.
  • Expectations for neighborhoods with cannabis businesses (e.g. smell, facility security, etc.).
  • What is the next.
    • Notice of acceptance of the request.
    • Pre-application information session / webinar.

As the above makes clear, CRC is committed to advancing the implementation of adult use. For example, at the last meeting on September 14, 2021, the CRC passed Resolution 2021-14, which approved NICUSA, Inc., to provide self-funded licensing and permitting software, which, according to the executive director, was a crucial first step in developing the application infrastructure. The meeting, in turn, is a crucial second step, which should clarify further regulatory nuances and prepare the general public for the long-awaited first round of adult use applications.

The content of this article is intended to provide a general guide on the subject. Specialist advice should be sought regarding your particular situation.

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