Ahead of the curve: A banker’s podcast episode 3 – Cannabis lending
To be blunt: The ins and outs of cannabis-related banking
Lending to and banking cannabis-related businesses is currently a hot topic among banking circles. With laws varying by state and the inherent risks associated with providing these services, many banks and credit unions are weighing whether to participate themselves. Ultimately, each institution will vary in its approach. However, there is no denying that this is a ‘budding’ industry that deserves serious consideration as a viable way to reach revenue goals.
In this podcast, we discuss:
- The definitions of common terms and the specific laws that go along with them
- Direct vs. indirect cannabis lending and the associated risks
- How this type of lending can be a crucial revenue source for your FI
Check out the series!
Ahead of the curve: A banker’s podcast
Looking for ideas, tips, and best practices to take your financial institution to the next level? Look no further than this podcast featuring insights from banking leaders and advisors across the industry. We’ll tackle a range of topics — technology implementation, loan grading, banking cannabis, and more to ensure you stay ahead of the curve in this fast-changing environment.
You can find all episodes of the podcast on abrigo.com or on your favorite podcast app or platform.
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Thomas Curley 0:00
This is Ahead of the Curve: A Banker’s Podcast
Thomas Curley 0:11
Welcome to our latest episode of Ahead of the Curve: A Banker’s Podcast. I’m your host Thomas Curley and I’m here with Terri Luttrell, Compliance and Engagement Director at Abrigo, and Kevin Gulledge, Senior Risk Management Consultant at Abrigo. Terri is CAMS audit certified and has 20 years in the banking industry. She’s worked in both medium and large institutions in the areas of compliance, fraud, commercial lending, and deposit operations. As an AML consultant, Terri has helped develop BSA and OFAC programs to ensure regulatory requirements are met and successfully managed at institutions across the country. Kevin brings over a decade of retail banking experience having worked with mid-size and large international institutions in a variety of roles including retail operations, compliance, and BSA/AML. Recently, Kevin has been working with institutions on best practices related to BSA/AML as well as calibrating and analyzing risk-based systems and working with BSA officers and regulators on both internal and external projects.
So welcome to the podcast y’all.
Kevin Gulledge 1:21
Thank you Thomas.
Terri Luttrell 1:22
Thank you Thomas, glad to be here.
Thomas Curley 1:24
Awesome. Well, it’s great to have you both on with, one, a fun topic but two a super important one as well. So I think we’ll hit both end of the spectrum there. I’m looking forward to the conversation. I did some research on cannabis related businesses and banking leading up to our call today. And one of the questions I initially had was, you know, what are the risk involved for financial institutions? But then I also started thinking about some of the potential growth opportunities it could present. So definitely both sides of the spectrum there. And I know we’ll get to both of those here in a second. But, before we dove in I thought it might be good to set the stage with some definitions that can maybe be commonly confused or might just need some clarification for our conversation moving forward today and kind of hemp verse marijuana. So Kevin I figured we’d start with you and maybe jump in and define those for us.
Kevin Gulledge 2:17
Sure. Yeah, so when we talk about hemp and marijuana, you know, there’s a legal definition that splits these two definitions. But let’s be clear whenever we talk about hemp and marijuana there’s really no difference when we talk about cannabis. Cannabis is the name of the plant, hemp and marijuana are just different flavors of the plant. So in the 2018 Farm Bill there was language in that bill that once passed, essentially legalized the production of hemp. And to legalize the production of hemp they needed to define what hemp was. And so if we look at a cannabis plant, let’s just start with a cannabis plant. If we look at a cannabis plant, there’s a lot of compounds and cannabinoids within the plant. And one of those compounds that you might have heard of is THC, tetra hydra cannabinol, I’m only going to say that once because it’s mouthful.
Terri Luttrell 3:16
Very good Kevin!
Kevin Gulledge 3:17
But THC, when we talk about hemp versus marijuana, hemp would be defined as the cannabis plant that has less than 0.3% THC in the plant. If it has more than 0.3% TCH it is considered marijuana, so just straight up seems a little arbitrary but that is how it is defined in in this current day and age. We’ll talk a little bit later about some of the nuances with this in terms of hemp and marijuana. We’ll talk about delta eight versus delta nine THC. I don’t want to throw too many terms at you right now, let’s just remember that for this definition cannabis is the name of the plant and hemp and marijuana are just different flavors. If it’s less than 0.3% THC it’s hemp, if it’s more than 0.3% THC it would be considered marijuana. Now you know Terri yeah, you know you can talk about some of the things that are happening at the state level. That’s one of the major things that we’ve seen at the federal level is that 2018 Farm Bill.
Terri Luttrell 4:23
Yeah, and thanks Kevin, I will talk about the state-specific things that you need to know. But being in the AML profession has led me to know a whole lot more about cannabis than I probably did even though I was a teenager in the 70s, so that is where our expertise comes from not from actual personal experience. I’ll lay that out there for you, but I’m going to address the state specific differently for the marijuana and the hemp. I’m going to start with the marijuana because that’s the trickiest one and the one with more risk. So as you know, at least half of the states now have some sort of legalization of marijuana. Many of them were just medicinal still but many of them and it’s coming on board more and more are the recreational. So we know that’s a factor. So can you provide lending services for marijuana related businesses? Well as Kevin said at the federal level marijuana is still illegal. It is substance one, just like heroin. It’s just there’s a risk there. For hemp, the Farm Bill did generally legalize that. So if you want to do some agricultural lending to the hemp business. your risk is much lower for that. The main thing you need to know whether you’re doing services for either of them is know your state laws. For hemp there has to be some state laws and licenses in place even though it’s federally legal so make sure that you know for hemp what’s going on, understand that your customers are in compliance with all of those regulations. For the states specific for marijuana you also need to know that very differently. You need to know your state’s laws, you need to know all of your state’s laws that are in your footprint. So all of your neighboring, they may be doing cross-border transactions. So it’s it’s a lot. The good news here is you can rely on the licensing boards for the states. Make sure their license are up to date, but they are regulated highly. So a lot of that, if you get documentation from the states, have your customers provide that enhanced due diligence documentation and then your risk is going to be lower. You don’t have to manage all of the knowledge of the state regulations.
Kevin Gulledge 6:38
Yeah, the 2018 Farm Bill I think, you know, is something that’s recognized nationally and it’s important to recognize that. But also at the same time drill into what’s going on with state laws. You know several years back now, a few years back, we had the beneficial ownership rules that have come down. These are still in play so in terms of capturing this information, you know, you’re still going to want to capture this information on these businesses and there’s always going to be risks involved with that and we’ll talk a little bit about the risks involved there. But with the 2018 Farm Bill legalizing hemp production, marijuana is still not, you know, even though we have all these state laws in place. So, critical to understanding state versus Farm Bill, Farm Bill versus state, vice versa, and making sure that we’ve got all those bases covered. And one last thing that I’ll leave there is to say if you’re currently using terms in your policies and procedures that say marijuana or hemp, it’s fine, I mean as long as you can define it and you’ve got different you know processes and policies for both. But it may just make more sense to move to the cannabis related business term and more of an umbrella term there. So, that’s one more thing I’d put in there about understanding the laws and just understanding your own internal, you know, policies, procedures, and program.
Terri Luttrell 7:53
Yeah, totally agree Kevin. And this seems to be the way we’re describing it, a little bit overwhelming, but it really isn’t. There are so many ways that you can learn besides what we’re just talking about today. I came from an AML background but didn’t really know much about cannabis until it started becoming a banking topic. So researching it, there’s so many free webinars out there today. That’s maybe one of the only good things about the pandemic, but sign up for those, learn them, learn the basics. Go to your state websites and find out what your state can do. Follow FINCEN’s guidance on marijuana, there’s lots of them. So the resources are there. Don’t think it’s over your head or too risky for you to take this endeavor. Later we will talk about the benefits of it and I am actually a proponent of cannabis banking. I think it can be done and mitigating the risk and I think it can be extremely profitable for the bank. So, I’m coming into this with an open mind and as you gain your knowledge I hope you can too.
Thomas Curley 8:54
Yeah, and Terry to your point you said, you know, you’re kind of a fan and you think that it can be used as a growth engine I think that’s a nice segue into kind of what we wanted to talk about kind of for this next section. You know what kinds of FIs are using cannabis right now as a growth opportunity?
Terri Luttrell 9:10
Interestingly, you’re saying growth opportunity. But and that’s the truth. It is a growth opportunity in more than one way, but surprisingly the smaller banks and credit unions have been the one to take the first step. And credit unions, you know, they’re member driven. They’re not in it for the profit. So they say, so we say, but they have been willing to take the risk and some of them have done it very very successfully. With the hemp legalization, it’s been a while now but it’s still taking a little bit longer just because of the risk and the risk of the unknown. So, when we’re talking about lending, probably hemp is going to be the first place you are going to be starting. You probably won’t start with the marijuana dispensary to make a loan. We will talk about the individual loans later, but the agricultural part is a great place to just tip your toes in this and see what you can do with your policies, procedures, get your examiners on board et cetera. But as we get more familiar with this and really if the federal government legalized marijuana there’s going to be so much interest in this. People are going to get on board, so from a competitive advantage it makes sense to research it now, get ready. Start with something littler, we’ll talk about the different risks in a straight dispensary versus some of the indirect. I think Kevin’s going to discuss that in a moment but it’s just not that that difficult. I think to try to get on the bandwagon, one thing I would keep in mind that we do have legislation. It’s called the Safe Banking Act relatively gives banking institutions a safe harbor if marijuana remains illegal. So, that’s very helpful for you to be able to say, okay, nobody’s going to come after me for money laundering because technically as long as marijuana is illegal you are money laundering. If you have proceeds from marijuana running through your federally insured bank, which is all of us. So, with that Safe Banking Act, if it ever does pass the senate and the congress approves it and it’s signed into law, that gives you that safe harbor. It has been stalled because a lot of people want just the flat legalization. They don’t think the safe harbor is enough, but come on Congress let’s do one step if you’re going to take forever to legalize marijuana and give the banks a chance.
Kevin Gulledge 11:35
And there are banks in this space. Banks are having success in this space as Terri’s mentioned. If you keep up with the SARS stats that the treasury and FINCEN put out, around 700 institutions are in this space and have been in this space really since the get-go. There was a little bit of an increase after the 2018 Farm Bill where we saw a little more institutions diving into this and being able to do it. But I’ve seen everything from the small one branch community operation up to the large multi-state, you know, hundreds of branches operations and everything in between have success with this. And it really depends on how far you’re willing to go and like Terri said maybe you dip a toe into some of this and with lending that’s generally the first place you’re going to do that. But you know some of the fee income from this can be astronomical. You know, a lot of these customers, these cannabis related businesses, they want to be in the banking system. So they’re willing to do whatever it takes to be in the banking system and if that means you pay a four figure a month fee, they’ll pay the four figure a month fee. It’s all about bringing this out of the shadows and into the light and the more we can do that the better off everyone will be. So, you know, institutions are in this space having success right now so why can’t you? And I think Terri, you know, raised those points very validly and, you know, just ask yourself why can’t we have success in this space? You know, there’s risks involved with everything, you know, are we willing to do what it takes to mitigate those risks? Sometimes you can point to this fee income and say, look you know if I can bank a few of these customers, make this fee income, well now I can afford to hire somebody else. So, it helps with staffing decisions and risk decisions down the road. So if you can get a leg up on your competitors I’m sure you would take any advantage you could get to get a leg up on your competitors and this is one of those areas that I think is rife for that. And cross-selling opportunities are going to be there, you know, with lending, with checking accounts, with savings accounts, with other things. You’ll have other opportunities. And perhaps even some really inventive products and services come out of this. I’ve seen banks get and credit unions get really creative with some of these things. So there’s opportunity there. There’s still a lot of green fields, green oceans out there so I would I would not discourage, you know, from thinking about this if it’s something where you think it’s in your risk appetite. Let’s explore those options.
Terri Luttrell 14:14
Yeah I totally agree Kevin and from the lending side just like any other loan, you should probably try to get your operating account, especially with a higher risk business so you can have your BSA team be watching the transactions, monitoring for that making sure there’s no illicit cash on top of the legitimate cash. So you can have the loan and origination fee if you normally would, but put it up because of the risk you have what Kevin was talking about the flat fee for your operating account plus account analysis. So there is so much opportunity for income in this space. I think Kevin really hit it on the head here.
Thomas Curley 14:54
And, you know, obviously Kevin alluded to, you know, whether you’re willing to take the risk or not. And that was kind of what we want to talk about next. Terri, what are some of those things that, you know, folks that get into the space or maybe that are thinking about starting a program around CRBs, what would you say to watch out for?
Terri Luttrell 15:16
Definitely cash. So cash is king here. This is very much a cash business until it’s federally legal, Most credit card companies are not jumping on board with the marijuana industry yet. But what to watch out for is the cartel money and these are real scenarios. The cartels especially in the western part of the United States, they’re finding legitimate marijuana dispensaries and other growing opportunities and they are forcing and coercing these legitimate business people to accept their dirty cash and run it through their businesses. So that is what’s so important about having your BSA team with your lending team. Y’all talk with each other and collaborate, but put the burden on BSA paid for by the fee income. They are going to have to balance that cash against two things, what they said was expected and what the state allows, you can’t just sell an unlimited amount of marijuana. So in each state will be different, so that you have to be able to know what’s expected based on state law and then if there’s an influx of cash you’re going to notice something’s wrong and your red flags are going to go up. That’s the biggest thing I think you need to watch out for because if your legitimate business gets caught, they have been money laundering whether they were coerced or not.
Kevin Gulledge 16:35
Totally agree with Terri. Totally agree, I think that when it gets into maybe not necessarily the agricultural aspect of this but when we start getting into the storefronts, the retail stores, and you know you could probably nowadays go down to Whole Foods and they’ve got CBD related products on the shelves. Well for your clients, where are those products coming from where are they being sourced from? Nowadays, there’s like I said there’s a lot of research going into the plants. You’re seeing a lot more compounds that are now being popularized, so you’re seeing things when we talked earlier about the definition of marijuana versus hemp we talked about the THC content of the cannabis plant. That’s technically delta nine THC. There is another compound within the plant called delta eight THC. Now this can be extracted from legal hemp plants, but how do you know that? Are you doing the site visits? Are you checking on these products? Again with state licenses, are you keeping up to date on that? You know there are there’s ways to extract CBD from a hemp plant or from a marijuana plant. So again, where are they being sourced from and it’s and it’s critical to understanding that. And again, you’re going to need to take, you know, them at their word right. I imagine you’d probably get a bunch of hands that would go up if you asked who wants to do a site visit and go try out these CBD products. I’m sure you’d get a lot of hands going up. But at the same time, it’s important to understand where those things are originating from. Are they originating from legal hemp plants depending upon maybe like the state of Texas doesn’t have you know the medical marijuana or the recreational marijuana like other states. So again, are we up to date on our state laws? Are we up to date on what products are truly legal and where are they sourced from? You know all of these are the risks involved with that and in turn you know we’ll talk about direct versus indirect care in just a moment, but I think that, you know, understanding the products and this goes for you know all your risky businesses right? You’re not just going to do this for hemp or marijuana, you’re going to want to do this for your liquor stores. You’re gonna want to do this for, you know, doctor offices, car dealerships things like that. Understanding source of funds. All that you’re going to be doing that for these businesses as well. So just critical to understanding, you know, where are these products coming from? Where are they making their money right?
Terri Luttrell 19:02
Yeah, one other thing I’ll add in here since we’re talking about the lending side of it is if you are in the grow lending, agricultural lending, maybe not, maybe marijuana if you’re that brave. Your loan collateral could literally go up in smoke if you are tested and you’re above that THC level that Kevin was talking about if you’re growing hemp. And that’s happening, so you really have to be in tune, get the lab reports from the customer that the state makes them do. It’s extremely important.
Thomas Curley 19:37
Terri how much does, I know we talked a little bit about it and you mentioned the western part of the United States, how much does an institution specific risk and where they are located affect maybe the opportunity this might present.
Terri Luttrell 19:51
Well, it’s just a matter of time. I mentioned western because Mexico is their border town and I’m I’m here in Texas, I see it as well, although we don’t have the legalization here yet. But in the northeast you have the cartels but you also have major crime organizations. Uou still have the Italians, you still have the Russians, you still have all kinds of different ethnic mobs that are into drug trafficking that are doing the same thing. So even though I said western as relating to that, that’s been in the news but assure yourself that it’s happening everywhere.
Thomas Curley 20:27
Well let’s go ahead and switch things up here for a minute. Kevin and Terri, I know we’ve alluded to kind of direct and indirect during our conversation already. Maybe we should, you know, level set and define that and maybe some of the different risk associated there. Kevin, do you want to jump in on the indirect side?
Kevin Gulledge 20:44
Yeah, direct versus indirect and, you know, we can look at this in different ways. So if we look at direct versus indirect, we’ll use some examples. So whenever we talk about direct versus indirect you know FINCEN and the Treasury, they’re helping to define this. You know, are you putting your hands on it?. Are you getting directly involved with the plant? Are you making the majority of your money from the plant? You know, that would be a direct relationship. An indirect relationship would be, just as an example, let’s say that you’re lending money to somebody who or an entity that owns a strip mall. Within the strip mall there’s a dispensary or within the strip mall there’s a CBD store, right? The CBD store is not paying the bank directly for rent or lease, they’re paying the landlord who then pays you. So that’s an indirect relationship and we’ll talk about some of the ways that you might want to look at these customers and risk-tiering. But, let’s just make that very simple. Direct or indirect. Director you’re in the plant, indirect it’s sort of indirect relationship with somebody who’s dealing with the plant. Terri did I miss anything on that?
Terri Luttrell 21:53
No I think that sounds good. Well the main reason of the distinction is the risk obviously. So you’ll need to decide as an institution, do you want to go with the direct? Do you want to do the plants, the growers, the dispensary, anyone who touches that funnel? Or maybe you want to start slower with some of the indirect. Maybe you just want that real estate strip center with the dispensary there or you can go as far as employees who work at dispensaries. They get their income from their jobs and they live in an apartment complex that you happen to be doing a loan for. Well that income is paying rent that goes to your loan. So yeah, the risk there is a little bit but what I suggest is doing a complete risk analysis on all of the direct versus indirect that you could possibly be providing services for and loans too. And then you can decide what your risk appetite is and drill down exactly what is the risk, what you’re going to do to mitigate that. Whether it’s staffing up, enhance due diligence, or working with your BSA team on the site visits to help you with all of that. That is what I would suggest is make sure that whatever you decide your board of directors is going to have to approve. It’s going to have to be in your policy, so they are the fiduciaries. They need to understand the risks as much as your research will lead you to understand.
Kevin Gulledge 23:23
I think all great points. You know, to further expand on the direct versus indirect, let’s think about it for just a second. Okay, so if somebody is a dispensary, they put their hands directly on the plant. If somebody is a grower or a distributor they put their hands directly on the plant. I’ve worked with Steve Kemmerling, he is a consultant, he doesn’t work for FINCEN or the Treasury. He has his own consulting firm, CRB Monitor and they’ve put together this risk tiering system. So this goes a little bit further beyond direct versus indirect. So direct again would still be somebody, they are a tier one sort of an entity. They put their hands on the plant, they’re making all of their money from the plant. This would be somebody that’s directly involved. They would be a tier one. Tier two and tier three is when we start to get into the indirect customers. So then it just becomes a question of are they working with a tier 1 cannabis business? Do they make the majority of their funds from a tier one cannabis business? So let me give an example. A marketing entity that creates marketing materials for cannabis businesses. Seventy-five percent of their business comes from cannabis, twenty-five from other entities. Well they’re making the majority of their funds from dispensaries, people that put their hands on the plant. They are an indirect business, although the majority of their funds are coming from a tier one. They’re still indirect because they’re not putting their hands on the plant but they could probably be considered the mid-level risk. And then we come down to a tier three which would again to use the same example, let’s say we have a marketing firm and twenty-five percent of their income comes from dispensaries the other seventy-five comes from other entities in other lines of business. So yes, making money from a tier one not making as much money as somebody who’s a tier two would be making from a tier one. But again, this just brings up questions of, how far do we risk matrix these customers? I could make the argument that the gas and the electric companies, you know, they’re giving you know electricity. They’re giving power. They’re giving, you know, heat to these customers that are growing cannabis. Is that the same? Is that, should I be considering my local utilities as an indirect tier three? Probably not, no I don’t think we need to go that far but it shows you how far we can go with some of these questions. So it’s critical that, yes, you make some risk decisions based off of this but at the same time we don’t want to get to the point where, you know, like does the does the utility company in this town provide electricity to these customers? How much of it? There’s questions that you’ll never be able to answer so it it becomes a question of how far do we go? How maximum do we start risk rating these customers? But the tier one, tier two, tier three, direct versus indirect that gives you some ideas there in terms of building out your policies and procedures. And again what terms are we using cannabis versus hemp versus marijuana. Let’s make sure we’re using the right terms. Get all of those documents updated, you know, with that risk tearing information. Now we’ve got a new process potentially for risk rating so that that can help with that risk rating process at account opening and through the ongoing process.
Terri Luttrell 26:47
Yeah, since we’re talking to a lending audience here most of the talk has been about business lending. Let’s talk about individual loans for a minute. You’ve got your car loans, you got your boats, and you got your mortgages. What about the people who do derive their income from the cannabis business? Will you be willing to take that risk to provide those personal loans as consumer loans? That is something for you to decide. It’s definitely not as risky as having a dispensary loan and having to monitor everything. But you do need to address that you will be providing individual loans possibly to people who derive their income from cannabis. That needs to be a risk your board of directors has approved in the policy because if you have made the decision, well we’re not going to lend to the cannabis industry but then this person that wants a car loan slips through the cracks your policy has a hole in it. So just be a little flexible in there and maybe the car loan person lies about where their income is, they don’t want to tell you where they work. Maybe you live in Texas and it’s not legal here and he works over in Oklahoma. Whatever so just know that you can say in your policy, we don’t knowingly provide lending services to cannabis related. And that way if they slip through the cracks and they haven’t told you the full truth about their source of income you’re okay. You catch it later, you address it at that time.
Kevin Gulledge 28:12
That’s a keyword there, knowingly. Knowingly. If you have that in there that helps. It’s a little catchall term, so just remember that one.
Thomas Curley 28:22
And before we jump to kind of our next you know topic you know Terri, Kevin do you feel like institutions are having or asking the right questions and are having the right conversations now as they think about this or do we think we’re we maybe in the pre-learning phase still.
Kevin Gulledge 28:39
That’s a great question. I think some folks are well ahead of the curve. I think some folks have been out in this space for years now. And how many years have we gone to ACAMS and this is, you know, the top topic at the at these meetings still to this day. So I think that if you can arm yourself with as much knowledge as possible like Terri said. Sign up for those webinars. You know we’ll host webinars, I’m going to be hosting a session on this at ThinkBIG, our conference, in a couple of months. So there are opportunities to learn more and I would just say soak it all in. Take in as much as you can. Talk to industry experts but there is definitely a learning curve here, there is no doubt about that. There is a learning curve here and some folks are, they are ahead of the curve. So it’s just matter of getting out there and learning really.
Thomas Curley 29:32
For sure. And I appreciate the podcast title plug early on Kevin, Ahead of the Curve or that’s what we’re attempting to do here right?
Kevin Gulledge 29:39
Ah, didn’t even notice I did that.
Thomas Curley 29:41
Well I know we’re running up on time here. You know ,Terri was there anything on enhanced due diligence that you thought was super important that we should bring up before we kind of closed it out here.?
Terri Luttrell 29:51
We have touched on most of it. But I’m going to stress again, site visits are a must. Kevin says everybody’s going to raise their hand and run out and want to go try the product. Whatever, that may be true, but just like if you have adult bars, bars and restaurants maybe with some adult entertainment, I’ve had banks provide services for these establishments but nobody’s willing to go to do a site visit with them. If you’re not willing to go into a dispensary yourself and you’re providing services. maybe that’s not the industry you should be in. You have to go yourself or send somebody who you trust to go see what that business is all about. Make sure it’s real. Make sure you don’t have armed guards that look like cartel people with AK rifles right there. It’s just something you have to do. Also know that you are gonna have to make those enhanced due diligence measures that are going to be costly. Probably additional staff, they have to be knowledgeable and that’s going to cost something. But you have your cost analysis because of your fee income, so you can definitely justify that.
Kevin Gulledge 31:01
State licensing. State laws. Understand what’s going on, especially if you’re multi-state and you know you’ve got a multi-state footprint. Make sure you understand those laws and licensing. So for those site visits make sure that we’re checking the right boxes and we’re getting the right documents from these folks. It’s going to be different sometimes from county to county, jurisdiction to jurisdiction. They might have different rules. I’m here in Colorado. The state of Colorado allows for recreational marijuana, there are some counties that just flat out don’t do it. So it’s important that you understand that if that’s happening locally. Just understand what’s going on with your local laws and, you know, again keeping in mind that of course there’s national laws that hopefully with the Safe Banking Act, you know, get passed. But just keep an eye on those and stay tuned on those. I wouldn’t hold my breath, but just stay tuned.
Thomas Curley 31:55
That awesome. Well let’s go ahead and maybe wrap it up. Terri, I know we’ve talked about this budding industry, but if folks were gonna take anything away from this conversation beyond just some of our fun jokes and stories today, what would maybe be your two takeaways.
Terri Luttrell 32:10
Well just to roll it up, Thomas. I’ll roll it up tightly for you. Just the risk analysis, look at your direct and indirect do your risk analysis to ensure it’s a good fit for your institution. Document everything that you do. The analysis didn’t happen if you document it and know it’s there and it needs to be especially important in this industry. As Kevin said, any higher risk industry. This is very cash intensive, it always will be so keep that in mind. Open the lines of your communication with your BSA team. This has to be a collaboration. Don’t make cannabis loans without them knowing. They have to be on board and be able to help you with the due diligence. And your regulators as well, tell them what you’re doing up front and get their buy-in. They’re not opposed to cannabis banking if it’s done right and they may even have some really good suggestions for you to sure everything up. And lastly, I will say take the money and run this is an opportunity for your institution.
Thomas Curley 33:12
Yeah, well said well. Thank you all so much for your time today. I really appreciate having you both on.
Kevin Gulledge 33:17
Thank you Thomas.
Terri Luttrell 33:18
Thank you Thomas, appreciate it.
Thomas Curley 33:20
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