“What does cannabis banking look like for my FI?” The short answer is that cannabis banking looks different for every FI. Here are some key topics to help you answer that question:
Assessing the Risk of Engaging with the Cannabis Industry
Information, news, rules, regulations, and attitudes are constantly changing. Which means you need a way to be able to stay on top of the variables that affect your ability to engage with cannabis-related businesses (CRBs). You need to make sure that you understand how external and internal factors will impact what cannabis banking looks like for your FI.
Engaging with External Factors
You’ll want to expand your CRB knowledge beyond what FinCEN Guidance requires. Making sure you understand the industry from every aspect of your FI. From your board of directors, to your compliance department, to your front-line staff. Here are some key examples of how to engage with external factors:
- As in all industries, there is a wide variety in the nature and quality of publications so we recommend starting with mainstream sites with a broad readership like these:
- Marijuana Business Daily
- Marijuana Moment
- Monitoring local CRB news.
- Every state has unique rules and regulations, the character of your state’s cannabis program will define the character of your FI’s cannabis program.
- Staying up-to-date on rule changes, is an essential part of your program.
Responding with Processes, Policies, Procedures, People
Understanding the current state of the processes, policies, procedures, and people is a great starting point for developing the foundation for a cannabis banking program.
- What processes, policies, procedures and people, etc. do you already have in place?
- Who and what will be impacted?
- What updates to your policies and procedures need to be made to account for cannabis banking?
Do I Have to Bank Everyone?
No. At the end of the day, you get to decide what cannabis banking looks like for your FI. Creating your programs based on the types of cannabis accounts you want in your institution is the best way to start the process. Some things to think about:
- Are you going to offer services to all CRB types (i.e. Dispensaries, Growers, Testing Labs, Delivery Services)?
- What kinds of services are you going to offer? Depositing cash is important for CRBs. Additional services such as loans, insurance and payroll services, to name a few. Are you planning to focus on deposits or do you want to offer other services in tandem?
- Remember, if your account holders don’t meet the expectations you set, they may not be a good fit. It’s important to make sure you have a strong exit strategy.
Schedule a demo to learn more about how Green Check can help you define what cannabis banking looks like for your FI.