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Cannabis Law Now Podcast: Inside a Top MSO with Jushi's EVP of Legal Affairs Matt Leeth

 

Published:

July 16, 2024
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There are now dozens of multistate operators (MSOs) in the U.S. cannabis industry. Since 2010, the concept of MSOs has carried many connotations, good and bad. At times, MSOs are considered the ultimate form of “Big Marijuana,” and at other times, they’re considered indispensable to the democratic experiment that is state-by-state legalization. Rarely do we get to peek into the daily inner workings of these MSOs, even though the overwhelming majority are publicly traded. In this episode, Husch Blackwell’s Hilary Bricken and Jushi’s Executive Vice President of Legal Affairs Matt Leeth discuss Jushi’s day-to-day happenings as well as long-term vision. Currently, Jushi operates 38 retail facilities and maintains roughly 1,200 employees throughout the U.S., while offering numerous cannabis brands to both patients and adult-use consumers. During this episode, Matt dishes on the challenges of scaling, regulatory differences from state to state, keeping investors happy, and what Schedule III will mean for Jushi and other MSOs.

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This transcript is auto generated

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welcome I'm your host Hilary Bricken and

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this is the Cannabis Law Now podcast

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where we regularly discuss issues

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related to the Cannabis industry

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including investment day-to-day

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operational issues and potential reform

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on the horizon that will impact all

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cannabis businesses and investors in the

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United

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States on today's episode of the

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Cannabis law Now podcast I am very lucky

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to have with me the EVP of legal Affairs

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at Multistate operator juy Matt Leeth

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thanks welcome to the show thanks for

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having me of course I think I don't know

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how many years ago now but multi-state

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operator used to be a fairly scary term

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in the industry because it really in

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some people's minds represented kind of

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large marijuana big marijuana what's it

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like being general counsel to a

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multi-state operator this day and age at

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a company like Jushi well you know I had

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started my cannabis career as a lawyer

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so to speak at The Green Solution in

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Colorado where we were just focused in

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Colorado there we had some some side

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action some some national plays going on

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but predominantly was not a multi-state

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oper was a single state operator there

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but a large one at Jushi I would say uh

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you know it started out as a infusion of

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capital from investors looking to invest

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in good assets operating Assets in the

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in in the US I would say what it's like

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working at Jushi has probably gone through

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iterations over the last give or take

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six years and it really started out as

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you know making prudent true investment

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decisions based off of good financials

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and forward-looking you know outlooks on

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how those market conditions will change

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but you know as time has gone on I would

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say you know working in a legal capacity

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legal compliance at Jushi as a multi

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operator really just means my head is

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filled with with multiple states of

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regulations and relationships with

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regulators and trials and tribulations

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of you know operating a national company

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that is you know predominantly siloed

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state to state so just as the business

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at Jushi as well as M other multiple you

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know companies Multistate operators has

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evolved you know it's about scaling

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businesses without the you know benefit

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of multi Multistate uh interconnection

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so it's definitely challenging it

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doesn't really scale intellectually in

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the same way that a lot of other you

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know traditional companies do however

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it's certainly been lots of opportunity

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at every turn when we're looking to

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launch things on a national basis I know

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you've been in the game for a while I

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have two and prior to

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2013 when we got the first coo it was

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dicey I think in many states with the

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exception the lone exception probably of

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Colorado which was already highly

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regulated I think as of 2010 what now

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does your typical day look like as a

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general counsel at Jushi you concerned

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about the federal government in any

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capacity anymore you know I I certainly

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am mainly from the perspective of you

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know what's coming next you know I'm

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sure we'll we'll still talk a little bit

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about that shortly but I would say I'm

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definitely more battle hardened through

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the years I'm sure you are as well

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counseling clients through the Cole memo

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the recision of the co memo and kind of

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where we stand today of sort of

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testimony about you know adhering to the

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principles of the co memo but the co

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memo not really existing like it once

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did you know I would say when I jumped

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in the industry in 2016 I came from a

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pretty traditional Telecom industry

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background so I really went from a

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highly regulated and matured industry to

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a very entrepreneurial challenging

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industry with Regulators um at a state

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level many of whom have never regulated

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businesses before and depending on the

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state could come from backgrounds

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skewing more towards law enforcement or

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taxation or Pharmacy and seeing the the

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philosophies kind of translated into

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those industries from those Industries

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into cannabis has created a lot of you

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know opportunity and sometimes

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roadblocks but at a federal level I

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think the biggest concern that we all

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sort of have but no one can really

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quantify yet is you know how the federal

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government will treat marijuana you know

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when it's schedule three and you know

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potentially descheduled all entirely in

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the future so it's many ways anyone's

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guess there and while I would hope that

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by the time these changes at are federal

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level are propos the industry has

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already been so entrenched in the way

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things are done in certain States but I

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do hope there'll be a dialogue with the

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federal government on you know how to

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best regulate the industry but you know

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it's it's anyone's guess and Jushi like

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most of our multi-state operators in the

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US is a publicly traded company I still

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think you have people scratching their

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heads over how a company can go public

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when it's technically illegally

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trafficking in a controlled substance

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was the go public process this difficult

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for Jushi yes it was and I'm sure it was

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difficult for every you know frankly

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every MSO that has gone in public in Jushi

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story it was a little late to the game

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in terms of formation it was formed in

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early 2018 by four key founders with

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varying backgrounds themselves but all

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of whom had been involved directly or

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indirectly in the canvas n for years

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prior to that and for gui's future it

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was a par it was Paramount that it went

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public you know pretty much as quickly

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as reasonably could and in 2019 that was

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a very chaotic year we went public in

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June of 2019 on the Neo exchange which

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has now been believe it renamed since

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then but when it went public you know

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went through a reverse merger structure

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up in Canada which was pretty much the

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the the playbook for cannabis companies

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to go public and that just like with

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spaxx in the US that Rose to prominence

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because you have these sort of shell

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publicly traded companies that could

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FastTrack incoming companies like Jushi to

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go public faster and economically which

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it just really was key to opening up the

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capital markets to the for the ability

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to expand not just necessarily

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horizontally across multiple States but

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in gui's case to really invest on going

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vertical as much as it reasonably could

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in in certain key markets so I think

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Jushi's success to date or at least its you

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know footprint is really thanks in part

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to going public when it did in 2019 you

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had sort of a a bust towards the end of

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the year in the Cannabis Market as sort

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of the I believe 2018

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Canada adult youth sort of induced

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fervor was starting to dissipate so I

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would speculate if we didn't go public

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as fast as we did we we may have been

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crowded out of the the opportunity for

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at least a couple of years until 21 or

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so when it he back up but long story

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short it was a very hectic time for the

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lawyers the financial folks and the

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leadership at Jushi going public and you

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had mentioned intellectual scaling right

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these businesses can't scale like your

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traditional business because of the lack

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frankly of interstate commerce given the

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federal illegality of cannabis truly

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hindering obviously it has multiple

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collateral effects regarding product

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Integrity the ability to expand the

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ability to organize and have oversight

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what is it like operating as an MSO

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given the current legal landscape it's

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really about trying to find efficiencies

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of scale when you can't have physical

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efficiencies created you know you've got

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scenarios where we we may have a very

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you know hot selling category in one

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state that we legally cannot produce in

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another um we've got you know

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nomenclatures or strain names that we

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can use in some markets and not others

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things like that which can really cause

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patient confusion but then really you

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know that I would say that's more the

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front of the house things that everyone

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could see the back of the house like the

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standard operating procedures and the

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national programs I mean Jushi has you

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know National Sanitation programs uh

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cultivation programs processing programs

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retail etiquette and slps what we do is

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we nationalize those programs as much as

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we can but then we'll have to have

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addendums or or similar Concepts on a

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state-by-state basis because even if it

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can produce the same products in one

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state or another we may not be able to

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grow in the same processing procedure in

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one state that we can in another so I

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would say you know a lot of those

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operational challenges translates into

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clients and legal questions that need to

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be solved which I'm you know thankful

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this Jushi maturity you know were there

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but that wasn't by luck that was a lot

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of effort and that wasn't just the

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lawyers or compliance team folks it was

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a lot of operational knowhow so you know

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the intellectual scaling is is just very

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difficult because you can't just come up

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with you know a GMP based process and

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procedure and then just rolling out and

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that's putting aside the fact that most

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States we operate in you know if you

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change one word in an sop you may have

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to submit that to a regulator and wait

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for them to okay it so you you know

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coming up with the plans is challenging

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rolling them out is challenging and in

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some cases you know rolling them out on

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time can be very challenging and the

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states this is truly a patchwork quilt

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of state-by-state laws and regulations

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no two are the same I still maintain the

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personal opinion that there's no gold

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standard out there for some reason

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states keep copying and pumping out

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maybe even the worst from each other

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depending on the program um much to my

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chrin I would hope that they'd learn

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from each other and and build up and

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make better and your opinion what's the

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best state that's been had for Jushi now I

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will tell you the the best state right

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now is frankly and this is strictly from

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a the sentiment of having a regulator

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that is proactively listening to the

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industry and not not to be told what to

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do of course how to regulate the

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industry but to listen to stakeholders

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that have been operating for years and

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sometimes you know years outside of the

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state that I'm speaking of but in

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Virginia you know we recently trans

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regulatory oversight recently

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transferred from the Board of Pharmacy

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which itself was a was a fairly Fair

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regulator but had a lot of

264
00:10:06,600 --> 00:10:10,600
pharmacological background that itself

265
00:10:08,640 --> 00:10:13,519
brought into the industry recently that

266
00:10:10,600 --> 00:10:15,079
translated transferred over to the CCA

267
00:10:13,519 --> 00:10:16,800
canas Control Authority and that

268
00:10:15,079 --> 00:10:19,279
leadership from everything I've heard

269
00:10:16,800 --> 00:10:21,040
has been very receptive to you know not

270
00:10:19,279 --> 00:10:22,839
just taking regulations that are on the

271
00:10:21,040 --> 00:10:25,000
books and accept accepting them as

272
00:10:22,839 --> 00:10:26,720
gospel but rather you know willing to

273
00:10:25,000 --> 00:10:28,560
listen to the industry to say why this

274
00:10:26,720 --> 00:10:30,800
may not work or why this could be

275
00:10:28,560 --> 00:10:32,600
refined in a different way and I I look

276
00:10:30,800 --> 00:10:35,000
at all those conversations not like you

277
00:10:32,600 --> 00:10:37,000
know steps steps backwards in any way

278
00:10:35,000 --> 00:10:39,040
for you know consumer health and safety

279
00:10:37,000 --> 00:10:41,480
but rather you know trying to help this

280
00:10:39,040 --> 00:10:43,079
industry continue to grow because it has

281
00:10:41,480 --> 00:10:44,839
been a very challenging industry and in

282
00:10:43,079 --> 00:10:46,880
certain States not Virginia is not

283
00:10:44,839 --> 00:10:50,000
necessarily one of them you know we have

284
00:10:46,880 --> 00:10:52,760
had just difficulties with

285
00:10:50,000 --> 00:10:54,240
efficiencies strictly due to you know

286
00:10:52,760 --> 00:10:57,000
operational burdens brought on by

287
00:10:54,240 --> 00:10:58,880
regulations so I really you know still

288
00:10:57,000 --> 00:11:01,519
have a very good sentiment and feeling

289
00:10:58,880 --> 00:11:03,000
towards CCA and their leadership um I've

290
00:11:01,519 --> 00:11:05,480
heard great things haven't really had to

291
00:11:03,000 --> 00:11:07,560
deal with them too directly yet but Ohio

292
00:11:05,480 --> 00:11:09,639
the transfer to all the control to

293
00:11:07,560 --> 00:11:11,600
division of cannabis control there you

294
00:11:09,639 --> 00:11:13,440
know their leadership I'm told is comes

295
00:11:11,600 --> 00:11:15,279
from a you know liquor regulatory

296
00:11:13,440 --> 00:11:16,880
background with sort of that same

297
00:11:15,279 --> 00:11:19,440
mindset whether you look at it as a

298
00:11:16,880 --> 00:11:21,279
medicine or you know an intoxicant or

299
00:11:19,440 --> 00:11:24,279
both you know the role of The Regulators

300
00:11:21,279 --> 00:11:25,920
is to ensure consumer and patient safety

301
00:11:24,279 --> 00:11:27,680
while letting the businesses run their

302
00:11:25,920 --> 00:11:29,360
businesses and I think that's sort of

303
00:11:27,680 --> 00:11:31,079
the sentiment I'm getting from Ohio

304
00:11:29,360 --> 00:11:34,040
those are my two top two right now that

305
00:11:31,079 --> 00:11:36,320
ju's dealing with and on the flip what

306
00:11:34,040 --> 00:11:39,480
have been the toughest States and and

307
00:11:36,320 --> 00:11:41,200
you may be surprising people here on

308
00:11:39,480 --> 00:11:42,560
what the toughest states have been and

309
00:11:41,200 --> 00:11:44,560
you know what do I mean when I say tough

310
00:11:42,560 --> 00:11:46,959
versus best you hit the nail on the head

311
00:11:44,560 --> 00:11:49,079
from the regulatory perspective with an

312
00:11:46,959 --> 00:11:51,160
eye to Consumer safety eye to public

313
00:11:49,079 --> 00:11:53,399
health and safety but also being

314
00:11:51,160 --> 00:11:56,000
business intuitive friendly investing

315
00:11:53,399 --> 00:11:58,000
and Innovation from that perspective

316
00:11:56,000 --> 00:11:59,920
what have the toughest States been maybe

317
00:11:58,000 --> 00:12:02,040
one or two if you don't mind

318
00:11:59,920 --> 00:12:04,760
so I'm not sure that I would necessarily

319
00:12:02,040 --> 00:12:06,399
tell you who states I I dislike

320
00:12:04,760 --> 00:12:08,120
currently especially ones that Jushi is

321
00:12:06,399 --> 00:12:09,720
currently operating within but I would

322
00:12:08,120 --> 00:12:11,760
say philosophically a lot of the things

323
00:12:09,720 --> 00:12:13,920
I was saying earlier about what makes a

324
00:12:11,760 --> 00:12:16,360
you know quote unquote good state to to

325
00:12:13,920 --> 00:12:18,199
operate in or or communicate with it's

326
00:12:16,360 --> 00:12:20,000
it's really the opposite of that one of

327
00:12:18,199 --> 00:12:22,079
the most frustrating things I think in

328
00:12:20,000 --> 00:12:24,199
operating in a state would be knowing

329
00:12:22,079 --> 00:12:25,720
there's a rule on the books that makes

330
00:12:24,199 --> 00:12:28,240
no sense from a patient health and

331
00:12:25,720 --> 00:12:30,279
safety perspective or truth and

332
00:12:28,240 --> 00:12:32,360
advertising perspec effective or is just

333
00:12:30,279 --> 00:12:35,160
otherwise Draconian without really much

334
00:12:32,360 --> 00:12:36,720
you know rationale for it being so and

335
00:12:35,160 --> 00:12:39,800
having a regulator that that's not

336
00:12:36,720 --> 00:12:40,920
receptive to listening and potentially

337
00:12:39,800 --> 00:12:43,399
of course you know going through a

338
00:12:40,920 --> 00:12:46,000
formal room making process to address so

339
00:12:43,399 --> 00:12:49,560
I will say historically um Nevada was a

340
00:12:46,000 --> 00:12:52,320
very tough State uh for Jushi um primarily

341
00:12:49,560 --> 00:12:54,600
from a entrance perspective they had a

342
00:12:52,320 --> 00:12:58,000
lot of we to say political drama and

343
00:12:54,600 --> 00:13:00,959
baggage um that had developed in 2018

344
00:12:58,000 --> 00:13:04,160
2019 under the Department of Taxation

345
00:13:00,959 --> 00:13:06,279
and then that transferred to the uh CCB

346
00:13:04,160 --> 00:13:10,000
but that wasn't an overnight switch that

347
00:13:06,279 --> 00:13:11,839
created a was audaciously long backlog

348
00:13:10,000 --> 00:13:13,880
for any changes of ownership

349
00:13:11,839 --> 00:13:15,639
applications or anything else that

350
00:13:13,880 --> 00:13:17,639
ultimately became the regulatory

351
00:13:15,639 --> 00:13:19,600
approval factor for us to be able to

352
00:13:17,639 --> 00:13:21,199
operate within those States and when

353
00:13:19,600 --> 00:13:22,880
you're in an industry that you know once

354
00:13:21,199 --> 00:13:25,600
you've made the investment decision and

355
00:13:22,880 --> 00:13:27,360
you've tied up the capital to enter aate

356
00:13:25,600 --> 00:13:29,480
every day you're not actually closing

357
00:13:27,360 --> 00:13:31,440
that transaction is is a lost

358
00:13:29,480 --> 00:13:34,519
opportunity so that was a very

359
00:13:31,440 --> 00:13:37,120
challenging State there were some uh you

360
00:13:34,519 --> 00:13:40,079
know interesting ways to help expedite

361
00:13:37,120 --> 00:13:42,480
the process here and there in Nevada um

362
00:13:40,079 --> 00:13:43,920
we we got through those processes you

363
00:13:42,480 --> 00:13:45,839
know had everything approved of course

364
00:13:43,920 --> 00:13:48,680
before we stepped into these licenses

365
00:13:45,839 --> 00:13:50,959
but at the end of the day um

366
00:13:48,680 --> 00:13:53,480
substantively having a regulator that

367
00:13:50,959 --> 00:13:55,519
listens to you and is willing to change

368
00:13:53,480 --> 00:13:57,160
the way things are done for for the good

369
00:13:55,519 --> 00:13:59,199
of the industry and for patients and

370
00:13:57,160 --> 00:14:01,040
consumers substantively it's very

371
00:13:59,199 --> 00:14:03,240
important but procedurally too having

372
00:14:01,040 --> 00:14:05,720
Regulators that respond quickly to

373
00:14:03,240 --> 00:14:08,160
Applications of any sort is is critical

374
00:14:05,720 --> 00:14:10,399
so well I won't name you know currently

375
00:14:08,160 --> 00:14:12,720
states that you know I dislike dealing

376
00:14:10,399 --> 00:14:14,240
with on a daily basis I would say if if

377
00:14:12,720 --> 00:14:16,240
you're a state regulator listening to

378
00:14:14,240 --> 00:14:18,440
this and you respond to Applications

379
00:14:16,240 --> 00:14:20,360
quickly and you know take a phone call

380
00:14:18,440 --> 00:14:23,880
from the industry then you're not one of

381
00:14:20,360 --> 00:14:26,240
those States I like that criteria okay

382
00:14:23,880 --> 00:14:29,519
now other question and I think a lot of

383
00:14:26,240 --> 00:14:31,720
people do want to know this from the MSO

384
00:14:29,519 --> 00:14:34,399
perspective because within have

385
00:14:31,720 --> 00:14:36,160
interstate commerce potentially Jushi has

386
00:14:34,399 --> 00:14:37,759
to set up a new entity with new

387
00:14:36,160 --> 00:14:38,720
licensing every time it enters a state

388
00:14:37,759 --> 00:14:40,720
or it's in these thirdparty

389
00:14:38,720 --> 00:14:42,680
relationships to expand the footprint

390
00:14:40,720 --> 00:14:44,480
whether that's IP licensing management

391
00:14:42,680 --> 00:14:47,440
companies whatever um could spand the

392
00:14:44,480 --> 00:14:49,480
gamut how are you dealing with what I'm

393
00:14:47,440 --> 00:14:52,040
going to call the banking epidemic and

394
00:14:49,480 --> 00:14:55,120
for everybody listening whether you're a

395
00:14:52,040 --> 00:14:56,399
seasoned cannabis operator or a newbie

396
00:14:55,120 --> 00:14:58,000
obviously access to financial

397
00:14:56,399 --> 00:15:00,240
institutions is very difficult because

398
00:14:58,000 --> 00:15:02,920
of federal illegality we really when I

399
00:15:00,240 --> 00:15:05,079
say we the industry only have one path

400
00:15:02,920 --> 00:15:06,880
to legitimate banking through the

401
00:15:05,079 --> 00:15:09,360
financial crimes enforcement Network

402
00:15:06,880 --> 00:15:11,519
guidelines from 2014 that enable

403
00:15:09,360 --> 00:15:13,240
financial institutions to just Bank the

404
00:15:11,519 --> 00:15:15,759
industry I'm not even talking about

405
00:15:13,240 --> 00:15:18,480
lending or anything else that are still

406
00:15:15,759 --> 00:15:21,160
around that did not get rescinded in

407
00:15:18,480 --> 00:15:23,040
2018 so how do you deal with that and

408
00:15:21,160 --> 00:15:25,759
especially as a legal counsel I know

409
00:15:23,040 --> 00:15:27,320
it's no picnic I represent a few Banks

410
00:15:25,759 --> 00:15:29,199
and just dealing with their compliance

411
00:15:27,320 --> 00:15:31,399
and reporting to their regulators this

412
00:15:29,199 --> 00:15:33,279
is a heavy lift with which to comply

413
00:15:31,399 --> 00:15:35,839
those guidelines yeah it's something

414
00:15:33,279 --> 00:15:37,560
that I'm sad to say that six years

415
00:15:35,839 --> 00:15:39,360
actually eight years into the industry

416
00:15:37,560 --> 00:15:41,319
there hasn't been much material change

417
00:15:39,360 --> 00:15:44,639
you know how cannabis company's bank I

418
00:15:41,319 --> 00:15:46,279
would say msos typically have I guess

419
00:15:44,639 --> 00:15:49,000
the the privilege I think of working

420
00:15:46,279 --> 00:15:51,160
with more banks that are willing based

421
00:15:49,000 --> 00:15:53,319
on their own risk perspectiv and their

422
00:15:51,160 --> 00:15:55,279
tolerances which cannabis companies they

423
00:15:53,319 --> 00:15:57,279
would work with I think I think we

424
00:15:55,279 --> 00:15:59,480
probably have more opportunities than a

425
00:15:57,279 --> 00:16:02,199
brand new upstart that's not well funded

426
00:15:59,480 --> 00:16:04,040
or well capitalized however it's still

427
00:16:02,199 --> 00:16:06,279
very challenging I don't know what the

428
00:16:04,040 --> 00:16:07,880
total count is currently as of today but

429
00:16:06,279 --> 00:16:10,279
you know we have many banking

430
00:16:07,880 --> 00:16:12,839
relationships and dozens of banking

431
00:16:10,279 --> 00:16:14,440
accounts across the US I would say

432
00:16:12,839 --> 00:16:16,360
cannabis dispensaries are still very

433
00:16:14,440 --> 00:16:18,839
much so a you know a cash driven

434
00:16:16,360 --> 00:16:21,839
business of course there has been you

435
00:16:18,839 --> 00:16:23,720
know one point credit card transactions

436
00:16:21,839 --> 00:16:26,000
that pretty much got shut down quickly

437
00:16:23,720 --> 00:16:28,279
you know five six years ago by by Visa

438
00:16:26,000 --> 00:16:31,120
Mastercard and has never really come

439
00:16:28,279 --> 00:16:33,480
back there there has been most recently

440
00:16:31,120 --> 00:16:36,000
uh point of banking terminals or in some

441
00:16:33,480 --> 00:16:37,920
cases debit terminals um those have had

442
00:16:36,000 --> 00:16:39,600
their own trials and tribulations

443
00:16:37,920 --> 00:16:41,600
they're fairly expensive I think when

444
00:16:39,600 --> 00:16:43,240
you consider when you go to any other

445
00:16:41,600 --> 00:16:45,079
retail store and use your debit card

446
00:16:43,240 --> 00:16:47,639
you're not being charged as a consumer

447
00:16:45,079 --> 00:16:49,560
any anything for the ability to do that

448
00:16:47,639 --> 00:16:52,399
but in almost every dispensary you walk

449
00:16:49,560 --> 00:16:55,079
into many of DUI's included you know

450
00:16:52,399 --> 00:16:57,040
there is a you know three or 350

451
00:16:55,079 --> 00:16:58,480
convenience fee and that's typically not

452
00:16:57,040 --> 00:17:00,959
a profit center for the cannabis

453
00:16:58,480 --> 00:17:03,440
companies that's just a uh you know

454
00:17:00,959 --> 00:17:05,199
basically a mitigation of the costs it

455
00:17:03,440 --> 00:17:07,319
it costs those companies to take that

456
00:17:05,199 --> 00:17:10,360
charges and that's generally because

457
00:17:07,319 --> 00:17:13,000
when you have rules and procedures in

458
00:17:10,360 --> 00:17:15,120
banking rules that crowd out all the

459
00:17:13,000 --> 00:17:16,679
federally chartered Banks and you're

460
00:17:15,120 --> 00:17:18,520
only dealing with State chartered Banks

461
00:17:16,679 --> 00:17:21,520
and you're only dealing with sort of a

462
00:17:18,520 --> 00:17:23,360
subset of uh Payment Processing vendors

463
00:17:21,520 --> 00:17:25,240
everything gets more expensive and then

464
00:17:23,360 --> 00:17:26,839
as the legal compliance side of things

465
00:17:25,240 --> 00:17:29,360
you have to be very scrutinous of these

466
00:17:26,839 --> 00:17:31,360
opportunities you know we I myself I

467
00:17:29,360 --> 00:17:34,039
have to put in the spam folder on a

468
00:17:31,360 --> 00:17:36,559
daily basis multiple credit card debit

469
00:17:34,039 --> 00:17:38,600
card point of banking type uh uh

470
00:17:36,559 --> 00:17:40,320
offerings because you know everyone is

471
00:17:38,600 --> 00:17:42,080
sort of blasting the industry trying to

472
00:17:40,320 --> 00:17:44,039
get each other's business but a lot of

473
00:17:42,080 --> 00:17:46,880
times you just have to really do your

474
00:17:44,039 --> 00:17:48,600
own kyc diligence on on knowing who

475
00:17:46,880 --> 00:17:51,160
you're working with it's you know for a

476
00:17:48,600 --> 00:17:52,919
company like Jushi we're very critical

477
00:17:51,160 --> 00:17:54,880
ensuring that you know our transactions

478
00:17:52,919 --> 00:17:56,640
are coded appropriately and that we're

479
00:17:54,880 --> 00:17:59,880
not dealing with any sort of kyc

480
00:17:56,640 --> 00:18:02,400
shutdown events from Merchant Banks

481
00:17:59,880 --> 00:18:05,280
however you know it's just a sort of a

482
00:18:02,400 --> 00:18:08,600
black box right now still for a lot of

483
00:18:05,280 --> 00:18:10,039
um those on the outside of of those

484
00:18:08,600 --> 00:18:11,600
companies those payment processing

485
00:18:10,039 --> 00:18:13,840
companies to know how the inner workings

486
00:18:11,600 --> 00:18:15,559
work it's just it's highrisk that's why

487
00:18:13,840 --> 00:18:17,640
they call it highrisk processing and

488
00:18:15,559 --> 00:18:19,679
that's only because of you know we don't

489
00:18:17,640 --> 00:18:22,440
have access to you know safe Banking Act

490
00:18:19,679 --> 00:18:24,559
enabled relationships with big Banks so

491
00:18:22,440 --> 00:18:26,960
I'm sure our CFO would love the ability

492
00:18:24,559 --> 00:18:28,960
to have you know one main bank account

493
00:18:26,960 --> 00:18:31,600
at a I'm not just saying any one you

494
00:18:28,960 --> 00:18:33,760
know Bank of America some large credible

495
00:18:31,600 --> 00:18:35,200
too big to fail type bank but you know

496
00:18:33,760 --> 00:18:37,120
those just aren't available to the

497
00:18:35,200 --> 00:18:39,120
Cannabis industry and it's incredibly

498
00:18:37,120 --> 00:18:41,600
challenging and frankly expensive to to

499
00:18:39,120 --> 00:18:45,000
operate in the current regime I to put

500
00:18:41,600 --> 00:18:48,480
those cannabis banking Solutions emails

501
00:18:45,000 --> 00:18:51,440
and promotions into my spam so you are

502
00:18:48,480 --> 00:18:54,760
in good company another question just to

503
00:18:51,440 --> 00:18:56,720
Pivot because msos to me are still

504
00:18:54,760 --> 00:18:59,840
fascinating I think they're carrying the

505
00:18:56,720 --> 00:19:03,440
load of a lot of progress definitely a

506
00:18:59,840 --> 00:19:06,200
lot of Market action let's talk briefly

507
00:19:03,440 --> 00:19:08,320
about hemp derived intoxicating

508
00:19:06,200 --> 00:19:10,039
cannabinoids and for those of you who

509
00:19:08,320 --> 00:19:12,440
don't know this at least to me in my

510
00:19:10,039 --> 00:19:15,280
opinion is a separate segment of the

511
00:19:12,440 --> 00:19:18,320
entire marijuana industry derived from

512
00:19:15,280 --> 00:19:20,080
the passage of the 2018 farm bill and

513
00:19:18,320 --> 00:19:23,320
without getting into the excruciating

514
00:19:20,080 --> 00:19:26,080
details of that law they apparently

515
00:19:23,320 --> 00:19:28,320
allegedly is a path for hemp derived

516
00:19:26,080 --> 00:19:32,280
intoxicating cannabinoids that don't

517
00:19:28,320 --> 00:19:34,919
amount to more than 3% THC and these

518
00:19:32,280 --> 00:19:37,400
products are taking the form of

519
00:19:34,919 --> 00:19:40,360
beverages Edibles you name it and they

520
00:19:37,400 --> 00:19:42,520
seem to be ubiquitous and also moving in

521
00:19:40,360 --> 00:19:45,080
interstate commerce and there's a very

522
00:19:42,520 --> 00:19:46,760
healthy amount of debate regarding the

523
00:19:45,080 --> 00:19:49,640
legality

524
00:19:46,760 --> 00:19:52,679
legitimacy the origin of how these

525
00:19:49,640 --> 00:19:55,799
products are made and as an MSO Matt and

526
00:19:52,679 --> 00:19:58,120
a GC for an MSO popular one what do you

527
00:19:55,799 --> 00:20:00,799
think of these products and are they

528
00:19:58,120 --> 00:20:03,799
crowding market share is there concern

529
00:20:00,799 --> 00:20:06,400
over them what's your general sentiment

530
00:20:03,799 --> 00:20:09,320
well I would say look at the end of the

531
00:20:06,400 --> 00:20:12,080
day Jushi exists for its shareholders and

532
00:20:09,320 --> 00:20:15,520
if Jushi found a pathway that it felt

533
00:20:12,080 --> 00:20:17,640
reasonably and legally confident in the

534
00:20:15,520 --> 00:20:19,840
ability to enter that market I wouldn't

535
00:20:17,640 --> 00:20:22,000
say that Jushi wouldn't enter it but as it

536
00:20:19,840 --> 00:20:24,799
stands right now as you sort of

537
00:20:22,000 --> 00:20:26,760
mitigated the way you were framing it I

538
00:20:24,799 --> 00:20:28,320
think there is a lot of ambiguity here

539
00:20:26,760 --> 00:20:30,640
there's a lot of gray area and there's a

540
00:20:28,320 --> 00:20:32,120
lot of interpretation um going on right

541
00:20:30,640 --> 00:20:35,120
now which has sort of

542
00:20:32,120 --> 00:20:37,480
fostered frankly you know explosion of

543
00:20:35,120 --> 00:20:40,000
the industry in the last 18 months or so

544
00:20:37,480 --> 00:20:41,960
Jushi went public in 2018 just for example

545
00:20:40,000 --> 00:20:45,600
the farm bill that is currently in

546
00:20:41,960 --> 00:20:47,360
effect that enabled this 3% THC carve

547
00:20:45,600 --> 00:20:49,000
out to the definition of marijuana under

548
00:20:47,360 --> 00:20:51,840
the Controlled Substances Act was also

549
00:20:49,000 --> 00:20:53,640
in 2018 but I think anyone who was

550
00:20:51,840 --> 00:20:56,080
reasonably close to the industry at the

551
00:20:53,640 --> 00:20:59,440
time knew very well that that was meant

552
00:20:56,080 --> 00:21:03,320
to be a non- intoxicating cannaboid

553
00:20:59,440 --> 00:21:05,760
Carval I.E CBD which is why you saw the

554
00:21:03,320 --> 00:21:08,760
CBD industry sort of Unleashed almost

555
00:21:05,760 --> 00:21:12,039
overnight once that farm bill was passed

556
00:21:08,760 --> 00:21:15,000
um and then you sort of had this glut of

557
00:21:12,039 --> 00:21:17,520
over production in the CBD space and it

558
00:21:15,000 --> 00:21:18,799
was determined by very people smarter

559
00:21:17,520 --> 00:21:21,720
than me that you could chemically

560
00:21:18,799 --> 00:21:24,520
convert CBD to Delta 8 THC through a

561
00:21:21,720 --> 00:21:27,039
fairly rudimentary process um so then

562
00:21:24,520 --> 00:21:29,159
you saw this influx of you know mildly

563
00:21:27,039 --> 00:21:31,799
but still mild moderately

564
00:21:29,159 --> 00:21:33,559
uh intoxicating products called Delta a

565
00:21:31,799 --> 00:21:36,000
and then more recently there's a couple

566
00:21:33,559 --> 00:21:38,039
of different sub interpretations to it

567
00:21:36,000 --> 00:21:40,080
but the bottom line is there there is

568
00:21:38,039 --> 00:21:42,520
now a sort of a camp and or there's an

569
00:21:40,080 --> 00:21:45,799
industry that believes that because the

570
00:21:42,520 --> 00:21:48,880
hemp being grown is very low and THC but

571
00:21:45,799 --> 00:21:50,720
is high in thca the precursor to THC

572
00:21:48,880 --> 00:21:53,480
that it still fits within the confines

573
00:21:50,720 --> 00:21:56,039
with that exception in the mean time

574
00:21:53,480 --> 00:21:58,640
with legalization of the state regulated

575
00:21:56,039 --> 00:22:00,679
marijuana Industries you you've seen

576
00:21:58,640 --> 00:22:02,600
over time even in states that aren't

577
00:22:00,679 --> 00:22:04,480
legal for adult use like here where I'm

578
00:22:02,600 --> 00:22:06,000
in in Florida you you can't just walk

579
00:22:04,480 --> 00:22:08,240
into a dispensary you have to have a

580
00:22:06,000 --> 00:22:11,000
medical marijuana car that's recertified

581
00:22:08,240 --> 00:22:13,039
every every seven months um and a state

582
00:22:11,000 --> 00:22:15,640
C that's issued every year just for the

583
00:22:13,039 --> 00:22:20,240
ability to buy medical marijuana let's

584
00:22:15,640 --> 00:22:22,400
say with 15 20% thca in in the regulated

585
00:22:20,240 --> 00:22:24,320
Industries as I call it maybe that's

586
00:22:22,400 --> 00:22:26,679
that's too aggressive you know when you

587
00:22:24,320 --> 00:22:29,279
look at THC you're looking at THC from a

588
00:22:26,679 --> 00:22:31,240
conversion factor which includes thca

589
00:22:29,279 --> 00:22:33,159
included in that but because of the way

590
00:22:31,240 --> 00:22:36,200
the farm bill was crafted there are many

591
00:22:33,159 --> 00:22:38,640
that believe that you do not count thca

592
00:22:36,200 --> 00:22:41,000
per purposes of determinate determining

593
00:22:38,640 --> 00:22:43,720
if the source product is hemp or

594
00:22:41,000 --> 00:22:45,440
marijuana and if you can come to the

595
00:22:43,720 --> 00:22:48,360
intellectual conclusion that what you're

596
00:22:45,440 --> 00:22:50,559
holding in your hand is hemp then you

597
00:22:48,360 --> 00:22:52,080
can extract it you can concentrate it as

598
00:22:50,559 --> 00:22:54,520
much as you want and it's still

599
00:22:52,080 --> 00:22:56,640
considered hemp there's been so much law

600
00:22:54,520 --> 00:22:58,600
enforcement and general regulatory

601
00:22:56,640 --> 00:23:00,960
enforcement ambiguity over the years

602
00:22:58,600 --> 00:23:04,200
years it's also sort of opened up the

603
00:23:00,960 --> 00:23:07,039
opportunity to having very aggressive

604
00:23:04,200 --> 00:23:09,200
sales of these products going on and I

605
00:23:07,039 --> 00:23:11,440
will say a personal opinion it's very

606
00:23:09,200 --> 00:23:14,039
frustrating having been in the state

607
00:23:11,440 --> 00:23:15,640
regulated side for eight years and seen

608
00:23:14,039 --> 00:23:17,360
you know a dozen different states up

609
00:23:15,640 --> 00:23:20,559
close and how they regulate their

610
00:23:17,360 --> 00:23:24,480
products um how you know aggressively

611
00:23:20,559 --> 00:23:27,480
taxed uh and tested and frankly limited

612
00:23:24,480 --> 00:23:29,720
on how we can Market our products while

613
00:23:27,480 --> 00:23:32,640
now you've got the sort of parallel

614
00:23:29,720 --> 00:23:34,159
industry that has essentially no rules

615
00:23:32,640 --> 00:23:36,480
subject to even you know subject to the

616
00:23:34,159 --> 00:23:39,279
FTC stepping in that you you can't

617
00:23:36,480 --> 00:23:41,559
blatantly copy you know trademarks of of

618
00:23:39,279 --> 00:23:42,559
other food products um but other than

619
00:23:41,559 --> 00:23:44,480
that there's been very little

620
00:23:42,559 --> 00:23:46,200
enforcement against this industry you

621
00:23:44,480 --> 00:23:48,159
are seeing some states start to clamp

622
00:23:46,200 --> 00:23:50,000
down on this and that's coresponding its

623
00:23:48,159 --> 00:23:53,320
own state-based

624
00:23:50,000 --> 00:23:54,960
leg lawsuits and litigation challenging

625
00:23:53,320 --> 00:23:58,159
whether states can do that when the farm

626
00:23:54,960 --> 00:23:59,400
bill arguably supersedes it so you know

627
00:23:58,159 --> 00:24:02,080
there are a lot there's a lot of

628
00:23:59,400 --> 00:24:04,640
tentacles to that question I would say I

629
00:24:02,080 --> 00:24:06,400
would say the most frustrating part is

630
00:24:04,640 --> 00:24:08,640
um you know this is an industry that I

631
00:24:06,400 --> 00:24:11,440
live in that live and work in that is

632
00:24:08,640 --> 00:24:13,600
highly taxed highly regulated we have

633
00:24:11,440 --> 00:24:16,360
always looked at ourselves like we are

634
00:24:13,600 --> 00:24:19,120
out there proving to the general

635
00:24:16,360 --> 00:24:20,880
populations that this is a safe product

636
00:24:19,120 --> 00:24:23,200
that can be sold that can be marketed

637
00:24:20,880 --> 00:24:24,720
appropriately it can you know they take

638
00:24:23,200 --> 00:24:26,559
a look at the coal memo we can do all

639
00:24:24,720 --> 00:24:29,240
the things that the coal memo wants us

640
00:24:26,559 --> 00:24:31,399
to to do or not do and yet this is sort

641
00:24:29,240 --> 00:24:34,399
of an unregulated Wild West industry

642
00:24:31,399 --> 00:24:36,520
with the thca intoxicating cannaboids

643
00:24:34,399 --> 00:24:39,600
that's that's unfolding and it's it's

644
00:24:36,520 --> 00:24:42,000
fairly it's enigmatic because it's not

645
00:24:39,600 --> 00:24:43,640
really clear other than analyst

646
00:24:42,000 --> 00:24:46,039
estimates how big the industry is

647
00:24:43,640 --> 00:24:48,159
getting because these are predominantly

648
00:24:46,039 --> 00:24:50,399
almost exclusively privately held

649
00:24:48,159 --> 00:24:51,960
companies not publicly traded companies

650
00:24:50,399 --> 00:24:54,399
which if you ask me that that's

651
00:24:51,960 --> 00:24:56,520
indicative of how uncertain the legal

652
00:24:54,399 --> 00:24:58,520
landscape is with that industry and at

653
00:24:56,520 --> 00:25:00,760
the outset of our conversation you

654
00:24:58,520 --> 00:25:02,679
mentioned the potential move to schedule

655
00:25:00,760 --> 00:25:04,520
3 for cannabis from schedule one to

656
00:25:02,679 --> 00:25:05,919
schedule 3 we know the Drug Enforcement

657
00:25:04,520 --> 00:25:08,320
Administration is reviewing the

658
00:25:05,919 --> 00:25:10,720
recommendations from the department of

659
00:25:08,320 --> 00:25:12,520
human health and safety they're Bound by

660
00:25:10,720 --> 00:25:13,799
the medical and scientific findings

661
00:25:12,520 --> 00:25:17,640
they're going to take as long as they

662
00:25:13,799 --> 00:25:19,840
take to make a rule either keeping it on

663
00:25:17,640 --> 00:25:21,799
schedule one or moving it lower

664
00:25:19,840 --> 00:25:25,840
potentially to schedule 3 what would a

665
00:25:21,799 --> 00:25:27,840
reschedule to three mean for Jushi and

666
00:25:25,840 --> 00:25:30,520
potentially the other msos that are in

667
00:25:27,840 --> 00:25:33,240
this very bizarre inability to

668
00:25:30,520 --> 00:25:35,799
intelligently scale somehow scaling

669
00:25:33,240 --> 00:25:38,320
anyway siloed state to state what would

670
00:25:35,799 --> 00:25:40,720
it mean for cannabis to become a

671
00:25:38,320 --> 00:25:43,559
schedule three controlled substance yeah

672
00:25:40,720 --> 00:25:44,399
it it's on on its face and I think most

673
00:25:43,559 --> 00:25:47,399
would

674
00:25:44,399 --> 00:25:50,960
agree the biggest clear effect it would

675
00:25:47,399 --> 00:25:52,200
have is eliminate the IRS code 280e

676
00:25:50,960 --> 00:25:56,840
which I know we're not going too deep

677
00:25:52,200 --> 00:25:58,279
into but um IRS IRC rather 280e apply

678
00:25:56,840 --> 00:26:00,640
specifically to schedule one and

679
00:25:58,279 --> 00:26:02,440
scheduled to drugs disallowing business

680
00:26:00,640 --> 00:26:04,399
deductions and other sort of ordinary

681
00:26:02,440 --> 00:26:07,039
deductions that ultimately creates a

682
00:26:04,399 --> 00:26:09,520
scenario where msos are paying effective

683
00:26:07,039 --> 00:26:12,159
tax rates which could exceed net income

684
00:26:09,520 --> 00:26:14,640
that's a huge Catalyst for the industry

685
00:26:12,159 --> 00:26:17,159
in and of itself how El you quantify

686
00:26:14,640 --> 00:26:19,240
what's to come I think it's a lot more

687
00:26:17,159 --> 00:26:21,080
subject to debate something schedule on

688
00:26:19,240 --> 00:26:23,480
schedule three is not necessarily

689
00:26:21,080 --> 00:26:25,960
something that you can sell over the

690
00:26:23,480 --> 00:26:27,840
counter without a prescription I.E this

691
00:26:25,960 --> 00:26:31,640
is not going to legalize adult use on

692
00:26:27,840 --> 00:26:34,640
its face there's always possibilities of

693
00:26:31,640 --> 00:26:36,679
sort of semi interstate commerce opening

694
00:26:34,640 --> 00:26:38,880
up on the medical space and potentially

695
00:26:36,679 --> 00:26:41,520
on the adult youth space um but it

696
00:26:38,880 --> 00:26:43,919
really remains to be seen how can a

697
00:26:41,520 --> 00:26:46,679
product that is sold both recreationally

698
00:26:43,919 --> 00:26:48,760
and medically on schedule three will

699
00:26:46,679 --> 00:26:50,640
exist in the interstate construct it's

700
00:26:48,760 --> 00:26:52,679
it's to me at least it's really not

701
00:26:50,640 --> 00:26:55,000
quite clear and until we start seeing

702
00:26:52,679 --> 00:26:58,720
real guidance come out either from the

703
00:26:55,000 --> 00:27:00,799
doj or the DEA or the FDA or anywhere

704
00:26:58,720 --> 00:27:03,520
else in between I would say it's all

705
00:27:00,799 --> 00:27:06,360
just speculation but I think the 280e

706
00:27:03,520 --> 00:27:08,440
solve in and of itself it is is worth

707
00:27:06,360 --> 00:27:10,240
dying on the hill over because that is

708
00:27:08,440 --> 00:27:12,440
crushing the industry as it continues to

709
00:27:10,240 --> 00:27:14,480
mature I think you're right about at

710
00:27:12,440 --> 00:27:17,279
least what the world would look like

711
00:27:14,480 --> 00:27:18,520
post rescheduling there's not a lot of

712
00:27:17,279 --> 00:27:21,279
scenarios where you can buy

713
00:27:18,520 --> 00:27:23,799
pharmaceutical drug and then it's twin

714
00:27:21,279 --> 00:27:24,799
recreational partner at 7-Eleven I think

715
00:27:23,799 --> 00:27:26,520
you're right there's a lot of

716
00:27:24,799 --> 00:27:28,880
speculation out there but I'm with you

717
00:27:26,520 --> 00:27:30,760
on the 280e release

718
00:27:28,880 --> 00:27:33,600
if you could choose today I'm just

719
00:27:30,760 --> 00:27:35,960
curious as GC for Jushi what federal

720
00:27:33,600 --> 00:27:37,600
regulator would you pick to oversee your

721
00:27:35,960 --> 00:27:39,880
business I cannot imagine that it would

722
00:27:37,600 --> 00:27:41,880
be the FDA even though they would be

723
00:27:39,880 --> 00:27:43,519
collateral because obviously we're

724
00:27:41,880 --> 00:27:44,880
talking about potentially Food and Drugs

725
00:27:43,519 --> 00:27:46,880
but who would you pick if you had your

726
00:27:44,880 --> 00:27:49,600
brothers when I started out I always

727
00:27:46,880 --> 00:27:51,600
looked at the products like a dietary

728
00:27:49,600 --> 00:27:54,039
supplement but that was a pretty naive

729
00:27:51,600 --> 00:27:55,640
sort of introductory Viewpoint I think

730
00:27:54,039 --> 00:27:57,480
on the product because the product can

731
00:27:55,640 --> 00:28:00,240
take so many different forms of

732
00:27:57,480 --> 00:28:02,720
ingestion inhalation intake and

733
00:28:00,240 --> 00:28:05,159
depending on the product and how perhaps

734
00:28:02,720 --> 00:28:07,320
the derivatives are compounded it can

735
00:28:05,159 --> 00:28:10,080
truly be a medical product or it can be

736
00:28:07,320 --> 00:28:12,080
a psychoactive recreational product so I

737
00:28:10,080 --> 00:28:16,600
think you know to your point I think

738
00:28:12,080 --> 00:28:19,720
treating the entire marijana sphere of

739
00:28:16,600 --> 00:28:21,840
of of product uh categories as one is

740
00:28:19,720 --> 00:28:23,600
problematic to me I think that means

741
00:28:21,840 --> 00:28:26,240
that you regulate it more like an

742
00:28:23,600 --> 00:28:28,480
over-the-counter a recreational product

743
00:28:26,240 --> 00:28:32,000
than you do a medical product which to

744
00:28:28,480 --> 00:28:33,840
me means you probably have a ttb type

745
00:28:32,000 --> 00:28:35,840
oversight I'm not saying regulate it

746
00:28:33,840 --> 00:28:37,720
like alcohol per se there's not a whole

747
00:28:35,840 --> 00:28:40,440
lot of you know therapeutic or medical

748
00:28:37,720 --> 00:28:42,640
reasons to you know take alcohol but at

749
00:28:40,440 --> 00:28:44,799
the same time I think that's probably

750
00:28:42,640 --> 00:28:46,360
the most analogous to what I see of

751
00:28:44,799 --> 00:28:48,320
successful Regulators at the state

752
00:28:46,360 --> 00:28:50,279
levels I think if you if you over

753
00:28:48,320 --> 00:28:53,960
regulate it like a medical product you

754
00:28:50,279 --> 00:28:56,080
you you start getting uh paralysis by

755
00:28:53,960 --> 00:28:58,120
analysis from the regulatory bodies in

756
00:28:56,080 --> 00:29:00,320
terms of allowing consumers to make

757
00:28:58,120 --> 00:29:02,159
informed decisions about the products

758
00:29:00,320 --> 00:29:03,399
certainly pre-market approval for

759
00:29:02,159 --> 00:29:05,120
cannabis products is totally

760
00:29:03,399 --> 00:29:07,760
inappropriate for something that's been

761
00:29:05,120 --> 00:29:10,519
legal or not existing for Millennia so I

762
00:29:07,760 --> 00:29:13,559
I think you know if you have a more

763
00:29:10,519 --> 00:29:15,760
alcohol analogous um regulatory

764
00:29:13,559 --> 00:29:17,440
oversight at the federal level I think

765
00:29:15,760 --> 00:29:20,840
that makes the most sense whether that's

766
00:29:17,440 --> 00:29:23,360
truly the ttb or you know newly formed

767
00:29:20,840 --> 00:29:24,919
body I don't know the answer to that at

768
00:29:23,360 --> 00:29:27,120
the end of the day though I think I

769
00:29:24,919 --> 00:29:29,159
would hope that any federal regulator

770
00:29:27,120 --> 00:29:31,519
stepping into this obviously within the

771
00:29:29,159 --> 00:29:34,320
confines of what the law allows them to

772
00:29:31,519 --> 00:29:36,240
do I I do hope they they listen to the

773
00:29:34,320 --> 00:29:38,159
industry as they step into it and not

774
00:29:36,240 --> 00:29:40,200
immediately think that they know how to

775
00:29:38,159 --> 00:29:41,960
regulate this industry just like I've

776
00:29:40,200 --> 00:29:44,080
seen at certain State levels that's

777
00:29:41,960 --> 00:29:46,600
where it's most problematic because this

778
00:29:44,080 --> 00:29:49,720
is still a very Nation industry dealing

779
00:29:46,600 --> 00:29:52,640
with issues operationally with OSHA

780
00:29:49,720 --> 00:29:55,640
other sort of run-of-the-mill Industry

781
00:29:52,640 --> 00:29:57,720
Regulators you know you see that these

782
00:29:55,640 --> 00:29:59,200
Regulators are all stepping into this

783
00:29:57,720 --> 00:30:02,000
you know not knowing how cannabis

784
00:29:59,200 --> 00:30:04,000
cultivation works or processing Works um

785
00:30:02,000 --> 00:30:05,880
so while their oversight and regulation

786
00:30:04,000 --> 00:30:07,919
is important it's also important for

787
00:30:05,880 --> 00:30:09,760
them to take an opportunity to listen to

788
00:30:07,919 --> 00:30:12,120
us and and explain you know how things

789
00:30:09,760 --> 00:30:14,559
are done where we see safety hazards

790
00:30:12,120 --> 00:30:16,399
where we see patient and C consumer um

791
00:30:14,559 --> 00:30:17,840
you know testing concerns things like

792
00:30:16,399 --> 00:30:19,519
that because I think we all need to have

793
00:30:17,840 --> 00:30:21,720
a Level Playing Field so we need to have

794
00:30:19,519 --> 00:30:24,279
a regulator that is regulating everyone

795
00:30:21,720 --> 00:30:26,240
whether it's you know hemp or cannabis

796
00:30:24,279 --> 00:30:27,519
or however you want to coin the products

797
00:30:26,240 --> 00:30:31,960
and treating it on an equal playing

798
00:30:27,519 --> 00:30:33,240
field final question and this one you

799
00:30:31,960 --> 00:30:35,200
know back to the beginning of our

800
00:30:33,240 --> 00:30:36,960
conversation msos I think used to strike

801
00:30:35,200 --> 00:30:39,360
fear in the heart of small cannabis

802
00:30:36,960 --> 00:30:41,880
businesses craft businesses smalltime

803
00:30:39,360 --> 00:30:44,200
Farmers Etc do you think msos are the

804
00:30:41,880 --> 00:30:46,679
future of regulated cannabis in the

805
00:30:44,200 --> 00:30:49,080
United States or at least the most well

806
00:30:46,679 --> 00:30:51,080
positioned to survive all of these

807
00:30:49,080 --> 00:30:54,360
macroeconomic issues that we're now

808
00:30:51,080 --> 00:30:56,639
seeing the turn and whims of regulators

809
00:30:54,360 --> 00:31:00,000
on a state-by-state basis if the states

810
00:30:56,639 --> 00:31:02,000
continue what are your thoughts on that

811
00:31:00,000 --> 00:31:04,519
I don't know how I would characterize

812
00:31:02,000 --> 00:31:06,120
them as the future per se I would say

813
00:31:04,519 --> 00:31:08,480
that they were it was an it's a

814
00:31:06,120 --> 00:31:10,720
necessary construct still today if

815
00:31:08,480 --> 00:31:13,200
you're an investor in the industry and

816
00:31:10,720 --> 00:31:15,279
want a diversified portfolio because as

817
00:31:13,200 --> 00:31:17,120
it stands today and frankly even you

818
00:31:15,279 --> 00:31:19,360
know after rescheduling it's still going

819
00:31:17,120 --> 00:31:21,519
to be predominantly State regulated

820
00:31:19,360 --> 00:31:23,679
State market conditions are are very

821
00:31:21,519 --> 00:31:25,559
much so in a vacuum in it all themselves

822
00:31:23,679 --> 00:31:27,279
so I think it's important for investors

823
00:31:25,559 --> 00:31:28,960
to be able to diversify their

824
00:31:27,279 --> 00:31:31,320
Investments with management teams they

825
00:31:28,960 --> 00:31:33,000
trust that said there are you know as

826
00:31:31,320 --> 00:31:34,880
far as the industry on the whole I don't

827
00:31:33,000 --> 00:31:37,320
think msos will be the only ones to

828
00:31:34,880 --> 00:31:39,720
survive you know the next phase of this

829
00:31:37,320 --> 00:31:42,000
industry there are certainly many good

830
00:31:39,720 --> 00:31:45,279
small operators sometimes at the quote

831
00:31:42,000 --> 00:31:47,159
unquote mom and pop shops I think msos

832
00:31:45,279 --> 00:31:49,960
that have been formed to dat for the

833
00:31:47,159 --> 00:31:51,919
most part of course Jushi included have

834
00:31:49,960 --> 00:31:53,960
put together you know have had the

835
00:31:51,919 --> 00:31:56,600
ability to put together great management

836
00:31:53,960 --> 00:31:59,200
teams that um come from other Industries

837
00:31:56,600 --> 00:32:00,720
as well or come from you know decade or

838
00:31:59,200 --> 00:32:02,679
more in the Cannabis Industries in

839
00:32:00,720 --> 00:32:05,320
certain states to really marrying those

840
00:32:02,679 --> 00:32:07,399
different professional backgrounds into

841
00:32:05,320 --> 00:32:09,200
growing these businesses in a healthy

842
00:32:07,399 --> 00:32:11,120
sort of risk adverse way and I think

843
00:32:09,200 --> 00:32:13,000
Regulators like when companies

844
00:32:11,120 --> 00:32:14,519
themselves are risk adverse so that you

845
00:32:13,000 --> 00:32:16,799
know they're not the ones having to find

846
00:32:14,519 --> 00:32:18,519
these things out after the fact so I

847
00:32:16,799 --> 00:32:21,799
don't know that we're the future in the

848
00:32:18,519 --> 00:32:23,480
sense of only msos Will Survive but I do

849
00:32:21,799 --> 00:32:25,000
think that when you start looking at

850
00:32:23,480 --> 00:32:27,320
when more and more money starts coming

851
00:32:25,000 --> 00:32:29,080
into the industry ideally through

852
00:32:27,320 --> 00:32:31,720
cannabis us cannabis companies being

853
00:32:29,080 --> 00:32:33,320
able to uplist into US markets you will

854
00:32:31,720 --> 00:32:35,279
see investors that will want to look at

855
00:32:33,320 --> 00:32:36,559
that pedigree of the management teams

856
00:32:35,279 --> 00:32:38,440
and you know how long they've been

857
00:32:36,559 --> 00:32:39,720
operating and that's a level of

858
00:32:38,440 --> 00:32:41,320
transparency I think you don't

859
00:32:39,720 --> 00:32:43,639
necessarily get with the small-time

860
00:32:41,320 --> 00:32:46,000
private operators but again you know

861
00:32:43,639 --> 00:32:48,080
especially in juu history when they were

862
00:32:46,000 --> 00:32:50,519
more on the acquisitive side of things

863
00:32:48,080 --> 00:32:53,039
we've met tons of good operators you

864
00:32:50,519 --> 00:32:54,480
know including ones we didn't acquire to

865
00:32:53,039 --> 00:32:56,720
that are in the industry that I think

866
00:32:54,480 --> 00:32:58,679
will be just fine but you know last

867
00:32:56,720 --> 00:33:00,279
comment I would say is

868
00:32:58,679 --> 00:33:02,120
you had mentioned about you know

869
00:33:00,279 --> 00:33:04,320
surviving the you know sort of the

870
00:33:02,120 --> 00:33:06,360
economic climate and you're really

871
00:33:04,320 --> 00:33:08,279
seeing that over the last you year and a

872
00:33:06,360 --> 00:33:10,519
half two years um anyone who could look

873
00:33:08,279 --> 00:33:13,080
at you know stock charts you know from

874
00:33:10,519 --> 00:33:15,720
2021 when there was a feror that you

875
00:33:13,080 --> 00:33:18,279
know the new uh Federal Executive Branch

876
00:33:15,720 --> 00:33:19,639
was going to you know do this or that

877
00:33:18,279 --> 00:33:22,120
which was going to open up the markets

878
00:33:19,639 --> 00:33:24,120
for cannabis companies you saw a big

879
00:33:22,120 --> 00:33:25,679
jump in stock prices because there's a

880
00:33:24,120 --> 00:33:27,279
lot more certainty towards growth and

881
00:33:25,679 --> 00:33:28,360
then as that certainty is kind of

882
00:33:27,279 --> 00:33:30,039
dwindling

883
00:33:28,360 --> 00:33:32,799
subject to the more recent you know

884
00:33:30,039 --> 00:33:35,039
schedule 3 announcements you've seen a

885
00:33:32,799 --> 00:33:37,000
real drying up they say of the capital

886
00:33:35,039 --> 00:33:39,320
markets which I think has really

887
00:33:37,000 --> 00:33:41,120
affected the smalltime operators the

888
00:33:39,320 --> 00:33:43,000
most I would say that the midsize

889
00:33:41,120 --> 00:33:45,120
private companies I would think are

890
00:33:43,000 --> 00:33:46,559
suffering the hardest right now um

891
00:33:45,120 --> 00:33:48,559
because it's very difficult to raise

892
00:33:46,559 --> 00:33:50,320
capital for larger companies let alone

893
00:33:48,559 --> 00:33:53,039
smaller companies and this level of

894
00:33:50,320 --> 00:33:55,240
uncertainty so you know I think msos

895
00:33:53,039 --> 00:33:57,399
just like going back to ju's history of

896
00:33:55,240 --> 00:33:59,919
going public as quickly as it reasonably

897
00:33:57,399 --> 00:34:02,519
could that was key for us to have the

898
00:33:59,919 --> 00:34:05,000
financial backing when the stock prices

899
00:34:02,519 --> 00:34:07,120
are are bad so to speak that we're not

900
00:34:05,000 --> 00:34:09,359
diluting our shareholders more than we

901
00:34:07,120 --> 00:34:11,960
than we really reasonably would need to

902
00:34:09,359 --> 00:34:13,760
to in order to withstand these issues um

903
00:34:11,960 --> 00:34:16,320
and we think these all are all fleeing

904
00:34:13,760 --> 00:34:18,359
issues that we will see progress in the

905
00:34:16,320 --> 00:34:20,800
industry certainly not as fast as we

906
00:34:18,359 --> 00:34:23,760
would like to have seen but nonetheless

907
00:34:20,800 --> 00:34:26,200
I think msos May survive as the time

908
00:34:23,760 --> 00:34:29,000
goes on more than the small operators

909
00:34:26,200 --> 00:34:30,919
but I don't know that just like in I I

910
00:34:29,000 --> 00:34:33,000
don't know that there will be a great

911
00:34:30,919 --> 00:34:35,040
Purge or anything and only msos are left

912
00:34:33,000 --> 00:34:36,919
standing I think when you look at the

913
00:34:35,040 --> 00:34:38,720
alcohol industry you've got macro

914
00:34:36,919 --> 00:34:40,480
breweries you've got micro breweries

915
00:34:38,720 --> 00:34:42,599
you've got single site Brewers you got

916
00:34:40,480 --> 00:34:44,240
Regional Brewers and while I don't think

917
00:34:42,599 --> 00:34:46,079
cannabis and alcohol is wer of the same

918
00:34:44,240 --> 00:34:48,159
the distri distribution models have kind

919
00:34:46,079 --> 00:34:50,280
of been created in very analogous ways

920
00:34:48,159 --> 00:34:52,280
state to state so I think you're going

921
00:34:50,280 --> 00:34:55,359
to see sort of that you know craft

922
00:34:52,280 --> 00:34:57,359
cannabis versus bigname cannabis sort of

923
00:34:55,359 --> 00:34:59,520
dichotomy grow in the industry as time

924
00:34:57,359 --> 00:35:02,760
goes up on but even the biggest names in

925
00:34:59,520 --> 00:35:04,480
cannabis AR in most of the states are

926
00:35:02,760 --> 00:35:05,920
currently so at the end of the day

927
00:35:04,480 --> 00:35:07,359
there's still a huge opportunity for

928
00:35:05,920 --> 00:35:09,760
brand recognition that's not yet

929
00:35:07,359 --> 00:35:11,079
realized hey well I appreciate that

930
00:35:09,760 --> 00:35:12,920
answer and I want to thank you for

931
00:35:11,079 --> 00:35:15,400
coming on to the podcast taking the time

932
00:35:12,920 --> 00:35:17,280
to talk with me today and I wish Jushi the

933
00:35:15,400 --> 00:35:18,839
best of luck we will definitely be

934
00:35:17,280 --> 00:35:20,599
watching great thank you so much for

935
00:35:18,839 --> 00:35:23,200
having

936
00:35:20,599 --> 00:35:26,000
me and that concludes today's episode of

937
00:35:23,200 --> 00:35:30,800
the Cannabis law Now podcast until next

938
00:35:26,000 --> 00:35:30,800
time stayler stay alive guys

Professional:

Hilary Bricken

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