With the growth of legal medical and recreational cannabis programs across the U.S., a well-developed playbook has emerged which can help financial institutions bank the cannabis industry more efficiently and effectively. A key component of this playbook centers on the policies and procedures banks and credit unions should adopt to ensure they are banking cannabis-related businesses (CRB) safely and compliantly.
But what exactly is a CRB? According to Steve Kemmerling, the founder and CEO of CRB Monitor, “because most institutions have not clearly defined ‘cannabis-related business,’ they may have unclear or incomplete policies and procedures that can lead to inconsistent interpretation and implementation.” We recently talked to Steve about the tiering system he developed to help financial institutions define, measure, and mitigate marijuana-related banking risk.
What is the CRB tiering framework, and why did you create it?
Steve Kemmerling (SK): I started CRB Monitor back in 2014 to help financial institutions comply with FinCEN guidance which recommends using publicly available information on CRBs to understand their nature, their licensing, their ownership, and other aspects of the business. As I was building out our corporate intelligence database, it became clear that there was no “one-size-fits-all” definition of ‘marijuana-related business.’
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