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  CCC Unveils Latest Round of
Proposed Revisions to Regulations
IBy Isaac C. Fleisher
t’s that time of year again. On July 20, the Cannabis Control Commission (CCC) revealed the latest round of proposed revisions to its regulations. Following a period of public comment and review, the CCC is scheduled to take a final vote on these revisions on Sept. 4.
Last year’s round of revisions made waves with two new categories of licenses (social consumption
and home delivery), but this year’s revisions are more focused on the owners behind the licenses. This is not too surprising because the demographics of license ownership has become a heavily debated (and litigated) topic.
When the CCC crafted its initial regulations (way back in the halcyon days of 2018), it included provisions intended to diversify the industry, such as a fast track to licensing for economic-empow- erment (EE) applicants, as well as fee waivers, training, and technical assistance for social-equity (SE) applicants. Even the new license types that were created under last year’s revisions to the regulations are initially reserved for EE and SE applicants. However, as small startups slam into the economic realities of the cannabis industry, it has revealed a tension between the need for capital and the need for equity.
The CCC’s latest round of draft revisions would require economic-empowerment applicants to satisfy at least one of the criteria related to ‘majority equity ownership’ and then report any changes of ownership and control when renewing their license. EE status is revoked if fewer than 51% of the owners meet the EE criteria. Similarly, the draft revisions specify that the various fee waivers and dis- counts available to SE applicants only apply to licensees with at least 51% SE ownership.
These changes would help prevent EE and SE certification from being turned into a commodity that could be purchased by investors that were never the intended beneficiaries. However, it would also further trap EE and SE applicants in the catch-22 of needing to raise millions in investment with- out giving up equity to investors that don’t satisfy the EE or SE criteria.
The draft revisions also seek to tighten the definition of
what constitutes ‘control’ over a cannabis business. This is
significant because Massachusetts prohibits any entity from Continued on page 62
 Revisions
Cannabis
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broad understanding of the process. Then, through individual courses, they can dig through each indi- vidual element.”
The goal, again, is to support both opportunities for job seekers and business growth, and Marrero sees elements of both in Holyoke’s enthusiastic adop- tion of the cannabis sector. He said Holyoke officials don’t “game the system” with host-community agree- ments, trying to squeeze as much from license appli- cants as possible. Instead, it’s a standard template that can be approved in a day.
“The CCC does its due diligence on businesses; we regulate things like land use and how businesses are integrated into the community,” he said of the city’s approach to license approval. “For us, it’s been about how to create jobs, how to help businesses get into the cannabis industry.
“It’s about creating a cluster,” he went on. “We’ve made a concerted effort to make it smooth, to work with industries to create a cluster. What it gets us is more than the sum of its parts; it’s how many jobs are created by these companies — and we have a dozen already special-permitted.”
Those services run the gamut from plumbers and pipefitters to security, delivery services, cleaning ser- vices, lawyers, and more.
“Any new company produces opportunities for other types of other businesses, and those businesses have to employ people. It’s that economic contagion that’s also attractive,” Marrero explained — one of the few times one might hear the word ‘contagion’ these days in a positive light.
Cannabis
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