The day you’ve been orchestrating for several weeks now has finally come! It’s time to launch your cannabis banking program. Getting things up and running is about much more than accepting your first deposit; it’s about understanding who will do what, and how and when you will define and measure the success of the rollout. You may be wondering what this has to do with your Board of Directors. It seems to be the kind of operational detail that Boards love to entrust to their teams. And while it’s true that it’s frontline intensive, your Board has decided to dedicate your institution’s human assets and capital toward this new line of business, and to take on higher-than-normal risk in the process. Accountability to your board as milestones are achieved, is the capstone of the work you’ve done to get your organization this far.
In our interviews with Board members and senior managers, they said they wanted to see a strong definition of the launch, as they would with any new product or service. They wanted to go in gradually, with one or a few “early adopter” accounts to learn how things were going before accelerating or expanding the programs. And they wanted clear identification of the milestones that will denote progress is on track or off the rails. And they wanted to see this laid out on a timeline they could easily understand and follow.
While every program will have its own unique elements, there are key milestones common to them all that are worth considering as you devise your customized rollout plan. Broadly speaking, these can be grouped into three phases that define before, during and after - we will call these phases of the rollout plan, launch, and refine.
There is a German adage that, translated to English says, “If you spend half your time planning, you’ll finish twice as fast.” The planning phase of the rollout can take anywhere from 30 to 90 days prior to your anticipated launch date. As with any significant rollout, you’ll want adequate time to build the implementation project plan, consider various stakeholder inputs, and define with precision the details of the tactical steps. Things you’ll want to be doing during this stage include:
- Define the project team. Identify who should (or shouldn’t) be included; you’ll want to consider not only managers but also frontline staff who will provide key insights to the ‘hands-on’ or ‘day-to-day’ considerations that are often overlooked by higher-ups.
- Determine roles, responsibilities and communication. Whether you use a recognized framework for your responsibility assignment matrix or something less formal, you’ll want to know who makes decisions, who has input to them, and who needs to be informed after a decision is reached.
- Identify the early adopters. Define which of your customers or members will be the first to transact business with you under the program, and how you will interact with their points of contact. Get them ready to provide you with the due diligence materials you will need to officially open their account, and work with them to transmit the files you’ll need to receive and confirm agreement on how they will make deposits.
- Document the plan. It ought to go without saying that you need a documented plan, with tasks, assignments, deliverables and deadlines - but you’d be surprised at how many teams try to “wing it” when it comes to this, especially if the teams are veterans and have been together a long time. There is simply no substitute for a well-articulated project plan to keep things moving along the intended path of progress.
- Conduct system and process testing. If you intend to rely on software systems to do some or all of the associated tasks of initial due diligence, account opening, or monitoring ongoing account activity, you will want to understand and validate how these systems will perform in a real-world scenario. Just as you would if doing a systems conversion, you will need to conduct dry-run or mock transactions to confirm things will be ready to go on day one of your launch.
- Train affected staff. Both at your financial institution and the early adopter client, you have to be certain that the staff who will be conducting business together have a full, clear and accurate understanding of what is expected, and how things will work.
The launch itself is the easiest phase. One you’ve worked out the kinks that showed up during testing, it’s time to hit the “go” button. The account is open, and it begins regularly receiving deposits. The main aspect of preparations for launch is to assure that the first several days of the new process receive extra scrutiny and oversight.
- Points of contact are in close, frequent communication. This allows any unforeseen issues can be quickly addressed. More than likely, a real-time, synchronous rollout takes place. What those fancy phrases mean is that your institution’s contact point, and your customer or member’s contact point, are on the phone or a web meeting, as the first few transactions are happening, to watch the process together and spot any challenges as they come up.
- Systems are synchronized. Any performance hiccups can be noted and systems recalibrated accordingly. This ‘day one’ approach of live coordinated oversight of the launch allows you and your customer/member to quickly spot and fix any bugs or correct any process misunderstandings.
Post-launch, the “refine” stage is all about checking in at various frequencies to adapt, make adjustments or enhancements, and shift from launch mode into maintenance mode. What you will check or validate depends on the time that has passed since the launch date of your program. These checkpoints also allow you to tie up any loose ends and confirm for your board that you are executing the plan as intended, or modifying it as needed, to meet the strategic objectives you set out to achieve. Some sample questions you’ll want to highlight in the post-launch discussions are:
- Day 1: Did the deposits process correctly? Did the communications protocols work as intended? Were the outcomes from the deposits visible and as expected?
- Week 1: Did our quality control and oversight processes for the daily work do what we intended? Do they need to be adjusted?
- Month 1: Did we see the transactional volumes, type and amounts that we expected to see based on account opening due diligence? Does anything unusual stand out that would require further investigation?
- Quarter 1: Validate that what is supposed to be happening in the account(s) is actually happening. This includes testing on a judgmental or statistical basis (depending on volume) to confirm that systems are capturing, collecting, filtering, transferring or flagging the data points they should, and that any processes for identifying and reporting suspicious activity are being followed. (Note: doing this sooner than 90 days may yield less reliable results.)
The end of the first quarter is also the time to conduct your first evaluation of the financial performance of the account itself. Are the fees you are generating in line with your strategic plan and your hypotheses around cannabis banking?
- Half-Year 1: At the six-month interval, you’ll want to repeat the analysis you did after quarter 1 - except that now you have two consecutive quarters of data from which to begin capturing trending information. If your early adopter accounts are behaving as expected and meeting the established performance metrics, now is the right time to consider adding other new accounts.
- Year 1: At the end of year one, you have four quarters of data and should have established a rhythm and been able to standardize and automate your operations even further. Now is the time for a formal, independent audit of your cannabis banking program, to assess not just your compliance with BSA/AML requirements, but also with operating standards you defined, and with financial performance metrics applied. This evaluation of the program’s effectiveness can help you make further refinements as you begin to set goals for your second year, including further growth or expansion of your cannabis banking program.
Congratulations - you did it! You’ve got a working cannabis banking program and are enjoying the rewards while minimizing the risks. You will continue to learn new things along the way, refine your programs as needed and respond to changing business conditions. When and if cannabis legalization at the Federal level takes place, you’re poised and ready to make shifts to add new business. Well done!