How Can I Sign Montana Banking Form

How can i industry sign banking montana form myself

the prevailing winds on cannabis finance nine days after an election where cannabis was on the ballot in several states and at the end of the of a year that saw significant congressional action on cannabis finance seems an opportune time to talk about it as a refresher for the audience why is cannabis finance an issue well cannabis remains illegal under federal law more and more states are legalizing cannabis in some fashion as well here shortly it has been fully legalized in canada there is increasing activity surrounding the cannabis business including m a deals ipos etfs um uh mutual fund solicitations even as recently as this morning and with banks investment advisors investors all are concerned at some level with becoming ensnared in in a violation of federal law in most cases money laundering despite all of this economic activity and although fincen and other regulators have developed a rubric for handling cannabis related proceeds there is still a lot of uncertainty in all manner of risk appetite around the industry so we will talk about that today with my panel of experts who all confront these issues nearly daily in their specific roles i'll just quickly introduce them to you i hope that you'll go to our website and review their full bios and by no means am i minimizing their accomplishments by just briefly touching on their background my first panelist is andrew klein he is the national cannabis industry association director of public policy um this rule was established at the end cia in 2019 and andrew leads that entity's substantive public policy efforts striving to prepare and protect the state legal cannabis industry he also leads ncia's policy camp council a group of its members focused on influencing state and federal public policy andrew was also the head of the national association the president of the national association of cannabis businesses which was the first self-regulatory organization for the high-growth cannabis industry and prior to that um andrew had many jobs in the federal government including as a federal prosecutor as a senior policy advisor in the executive office of the president under president obama and with the federal communications commission katrina carroll is the executive vice president and chief anti-money laundering officer for lpl financial and its affiliate the private trust company and she is a return guest to the cannabis to the cadwallader finance forum and our cannabis panel she is responsible for all aspects of the institutions anti-money laundering and ofac programs prior to that uh role katrina was in private practice at a very fine firm in washington dc where she canceled clients on all sorts of anti-anti-money laundering and regulatory matters and sanctions matters and she also served as outside counsel to sifma's anti-money laundering and financial crimes committee she too had a long career in the federal government and uh including terms at the securities and exchange commission and at the treasury department and finally last but not least doug fisher is the general counsel of greenland a public company listed on nasdaq gn ellen uh for those who are interested um it is the leading global platform for the development and distribution of premium cannabis accessories and lifestyle products so he will have a lot to say about how it feels on the ground to be a victim if you will of cannabis finance uh conservatism doug was previously at cad wallet or workership and theft which you all know since you're here at our finance forum he was an associate in my group um and he represented corporations and individuals in an array of settings uh across the white collar and regulatory space he worked with andrew at the national association of cannabis businesses he was the chief legal officer there and he has deep experience in a money laundering laws and controlled substances act um i'm going to get to my questions uh right now so andrew first can you tell us what's the state of play uh for all post-election in each of the states that have a cannabis initiative on the ballot are we going to be fully legal in the united states that's a loaded question thanks jody you know look we're seeing lots of momentum at the state level but uh still very little progress at the federal level so far with few exceptions where democrats have led uh but let's just start with the polling which is just off the hook you know there was a gallup poll about a year ago showing that 90 of americans supported legalizing medicinal cannabis and last week gallup had another poll which showed 68 of americans favoring legalizing recreational and progress at the state level on november 3rd was a 100 passage rate so for you political jumping junkies the cannabis industry received 538 electoral votes on november 3rd and nobody asked for a recount there were no lawsuits mike pompeo has not challenged our historic wins and we didn't need to hold a press conference at the four seasons everyone accepted our victories so um all five states that had ballot initiatives passed we now have 36 states that have medicinal cannabis programs 15 states now allow recreational sales so let's look at rec new jersey south dakota and arizona legalized recreational marijuana montana south dakota and mississippi legalized medicinal marijuana in new jersey the vote was 66 percent um which is which is a good high mark and and legalization in new jersey put some pressure on new york now in connecticut as a matter of fact the speaker of the house designee in connecticut recently said that he thought that legalization in connecticut was inevitable now because of new jersey in arizona the vote was 66 percent um and we already saw maricopa county starting to dismiss pending marijuana charges which is a pretty big deal maricopa county until this election was a pretty conservative county south dakota legalized both medical and recreational in one fell swoop which is pretty amazing with 66 in support of medical that's about um the same as as national polling on unrecreational in a very conservative state um in that state uh they spent 1.7 million dollars um for legalization as opposed to 200 000 on the campaign against legalization um and i forgot to mention in new jersey uh those numbers were 573 000 for legalization and 8 8 875 were spent in opposition um in montana 56 uh voted in favor that's the same percentage of votes um in california four years ago in california uh montana has been consistently a pretty red state so that's pretty impressive um in montana they spent uh 7.2 million as opposed to 307 million um excuse me 307 000 in opposition and in mississippi mississippi has legalized medical marijuana 4.7 million dollars was spent um on that campaign as opposed to 312 000 in opposition so lots of great progress at the state level so um you know those those numbers are are really um uh fascinating and and it seems like you know there's either either the the anti-legalizers are very poor or there's just not a lot of um momentum behind them anymore do you think that the results of these elections the fact that maybe legalizing or liberalizing were not hard fought that um you know we will see some changes at the federal level um and and i guess i would also ask you to comment on on whether the presidential and u.s senate electoral results um factor into these very overwhelming state successes absolutely look i mean i think there's no putting the genie back in the bottle at this point right um you know we we're seeing so much momentum at the state level that it's just really hard to ignore and i think we're going to start seeing some movement in congress soon you know on the more act and and potentially unsafe banking okay well let's let's talk about um both of those and then just for the audience who might not be um uh fully fully informed safe banking act was the was the anti-money laundering statute that essentially gave safe harbor to banks that um banked banks and financial institutions that banked state legal cannabis businesses the more act was actually a more expansive um not decriminalization but but rescheduling statute with a lot of social justice and expungement pieces in it um both were on the floor of congress this year and and at the end of the day neither passed andrew um ncia's view on on on what the problems were why those didn't ultimately get to votes in the senate um why moore didn't even get the hearing in the house that it was supposed to have um and why do you think that's going to change in the coming year yeah i mean look on safe banking um the bill passed by a vote of 321-103 in september of 2019 um and still hasn't even seen a hearing in the senate um you know mike crapo and mitch mcconnell have been pretty pretty hostile to cannabis have basically done less than zero uh to support safe banking or anything else but there have been some uh some positive indications in in recent days pat toomey who is likely going to be taking over the banking committee has indicated a willingness to consider holding a hearing on safe banking and he's retiring in two years he's not facing re-election so this could be a real opportunity for uh for the industry um and i think you know we really need as the industry we need to make the economic case uh to him um uh there's you know a medical market in pennsylvania um likely over a three billion dollar market in pennsylvania if they were to open it up to wreck um and pennsylvania is going to be losing um you know tax revenue to neighboring states um if they don't take some action so so on on safe i actually think um you know we could potentially see some movement in the senate um on the moore act we didn't we didn't have the votes in october and i'm assuming that there was a whip count recently because uh you know and and whip count showing that that war will pass because they have scheduled a floor vote in december um there's been you know no action in the senate and make no mistake there there won't be any action in the senate on this bill um even even when the house passes it but it'll set the stage for 2021 and 117th congress um the more act doesn't have a regulatory plan um and and it needs one and the industry really needs to get behind a regulatory plan that they want we actually published a white paper back in october of 2019 which you can find on our website that kind of lays out what we think that regulatory plan should look like we broke it down into four lanes so our recommendation is that the fda retain jurisdiction over pharmaceuticals so still do clinical trials and if you want to make health claims that's the lane for you um thc products above three percent would be regulated by the states uh the department of treasury and the fda and then ingestibles and topicals that fall below 0.3 would be regulated by the fda um and we think that cannabis should be deregulated like alcohol uh that there should be a role for fda and ttb and state regulators but a limited role for for dea um of course the first step you know is accomplished in the war act and that's removing cannabis from the controlled substances act but um you know we need to do some other things in that in that regulatory plan so you may have seen jody today the state regulators announced today that they formed an association and i think it's important for the federal government to step up and fund that association and really um coordinate with those those state regulators um and then at its most basic sorry no i'm sorry um get you off go ahead yeah it's just at its most basic level the the federal government's responsibility should be to register and tax the state legal entities to regulate interstate commerce and to set minimum standards on labeling and packaging and testing but at the end of the day we need to respect state sovereignty and let those state regulators do their job okay um so that was a lot i probably have 10 million questions there are 170 people out there watching and we encourage you to please submit questions uh we will try and get to some at the end which is why i'm going to move away from all my many follow-up questions for andrew and move on to katrina carroll so if you haven't um noticed what i had what we have is is the real sort of political lobbying arm the banking maybe where all of you are now and then the business person that's in the mix of this responding to everything so i think an interesting um point of view from all the panelists so well let's move to um katrina who who works at a regulated financial institution entity and and is a compliance expert on aml um katrina there's been since you last spoke at our finance forum which was about three years ago certainly there's been a lot of movement in the cannabis space and andrew just brought us up to date with a lot of great detail um what has changed from a compliance standpoint either speak generally about the industry or about lpl in particular um about dealing with um cannabis related customers meaning customers that have revenue not from direct plant touching activities but who might be adjacent to the cannabis business has anything changed for them in terms of being able to deal in a more open way with banks and other financial institutions broker dealers investment advisors hi everybody thanks for having me today um if i could just set the stage a little bit so lpl financial is a very large ubiquitous domestic wealth management firm but you can think of us as a string of small businesses so our advisors operate all over the country in communities where there are marijuana related either direct or adjacent thriving and if i could just put my publicly public policy or treasury hat back on for a second and add a little fuel to andrew's fire there's a real public safety issue in this conflict and by that i mean that local businesses are sitting on pallets of cash i spent like a decade in the federal government trying to get people out of cash and into the formal financial sector so this is a very perverse outcome of this this conflict um that's my soapbox description um but when you're at a wealth management firm like i like i am it's different than banks um we have to look at at least three levels here one is like you said marijuana related um customers um get back to that in a second marijuana related proceeds incoming and marijuana-related investments so it's a trifecta of issues for a firm like mine and on the marijuana related customers um there's a spectrum right so the direct sort of direct hit haha if you will is the the growers and the sorry i can't talk you can't believe it it's hard not to do it yeah i can't leave a panel without it um you know there's there's a very direct obvious right the growers and dispensaries but from then it becomes very very very very gray and so um different firms take different approaches by and large everyone is still prohibiting the obvious um you know full marijuana businesses that's all they do um other considerations so once you get beyond that to the gray area considerations include well is this a business that exclusively targets itself to the cannabis industry or is it just a small part of what they do you can almost think of it for the for the law school grads out there is like a substantial revenue test but this is not written down anywhere this is just sort of this equilibrium that the industry has kind of arrived at or at least some firms have um if you took it to its most absurd conclusion and you applied it you applied that that um that conservative approach you wouldn't be providing financial services to lowe's or home depot because they offer grow lights and soil that could be used by a cannabis related entity so obviously that's the other end of the spectrum and we're certainly not there um the biggest question so to answer your question about what has changed recently the biggest question i keep getting is okay we have a marijuana related or cannabis related client can we ring fence the funds that we accept and the business that we do with them to exclude those cannabis related proceeds and to your point these issues come up almost every day pre-covet i was spending probably 30 percent of my time on this and some of my peers spend more um and that requires a very bespoke solution and it requires a lot of different players at the table it's not just me it requires your supervisors it requires your surveillance and you have to really ask yourself you know is this what is our risk appetite for this and what are we willing to spend to achieve that very bespoked supervision and compliance arrangement okay so there's it sounds like there's some consideration and discussion but not open arm hugs yet no warm hugs i do i do think that um i do think that it will get a little cozier um in a biden harris administration uh i think that with the with the topsy-turvy statements from the um trump administration as to doj's approach here we were all just sort of paralyzed right i think i mean obviously vice president-elect harris has made her her vision clear and i i think there's a lot that that the administration can do without congressional action namely um prosecutorial priorities sort of reversion back to what we saw in the obama administration so i do predict some warming up so so on that uh prosecutorial um question so um just to remind everybody in the audience for for quite a long time um there there was in the justice department what was known as the coal memo which basically told federal prosecutors to prioritize marijuana cases only if they involved the types of activities that you would see in normal criminal drug trafficking organizations and otherwise not to spend precious federal resources on prosecuting cannabis cases even though it remained illegal sessions came in and famously undid the coal memo but there still has not been a huge um increase even in the trump administration of uh cannabis related prosecutions question for you katrina and then doug i'll ask you the same thing is is the risk of prosecution as low as it is something that gives comfort to financial institutions wealth management companies comp you know corporations operational corporations in the business does the fact that you know when i tell my clients look you know there is a risk that you are violating the controlled substances act and that you are violating the anti-money laundering laws but you will not get prosecuted for it so go forth um and profit is is that a comfort to folks like you katrina it is some comfort um i think that the problem of course is how am i as the aml officer how is my supervisory team supposed to know whether the business is or is not violating those priorities set forth in the coal memo and so it could appear to be a clean business that doesn't market to children or deal with organized crime or all of that but unless you're out there monitoring them how are you going to know so it's a it's getting us some comfort but there's still an awful lot of ambiguity so my thought is that the president-elect and vice president-elect if they want to use their executive branch tools they should go further um and try to figure out a way to use whatever they can absent senate action okay um and i i suppose that um you know compliance and the cost of compliance or are a big question obviously some entities pass those costs down to customers but the bottom line for everybody is that you don't get the benefit of the protection of deprioritized cannabis prosecution unless you are really only complying with the state laws which as andrew pointed out and katrina as you point out are are quite varied and we'll hear how doug manages it and i mentioned at the top um just coincidentally uh i didn't cause this to happen i got a solicitation today in my inbox to invest in a cannabis growth fund mutual fund vehicle um and uh they focus industry sector cannabis um manufacturing and dispensaries how can that fund bank its assets and and how do you think that um the bank that banked it and also the fund itself got comfortable with the risk that they are potentially violating either the controlled substances act or the anti-money laundering laws and and um what would you do if your client came in and said uh please put my money in uh uh 10x which is the name of the mutual fund um my immediate thought is canada and canadian banks as you know it's fully legal up there um and just as an aside a compliance point for our our uh physical presence by the northern border uh you might want to think about whether any of your uh and you know any of your customers are engaging in stuff in canada or perhaps at risk cross-border problems there um no it's a great question i had the same question about investment bankers that got comfortable so maybe i'll uh talk to doug offline about that um but obviously someone is banking them um and so it's possible that they have complex legal arguments that you know some of the the great wall street firms are pairing up with their with their um their criminal uh colleagues um i think you know if if i got the question my firm has a pretty robust product new product review process um and the expectation of regulators is that the aml team have a lens into that and we're quite conservative and very vanilla when it comes to that at my firm so i doubt that it would come on board until these complexities are resolved if you're talking about direct held positions at a fund company where our end client has a direct relationship with that fund company and we're the broker dealer of record then it becomes more murky there's a better argument that it's attenuated from us but there would be a lot of kind of mental gymnastics going on trying to look at that okay fair enough all right doug let me turn to you um is anybody having trouble hearing me by the way i'm getting a note that my audio is troublesome you guys good though yes okay it's in and out a little bit but you're you're okay okay thank you um doug can you tell us a little bit about um green lane and how it touches um cannabis and the cbd space sure and and maybe i should say it doesn't doesn't touch cannabis directly at least so thank you yeah so as you said at the top we're a global platform for distribution of cannabis accessories and lifestyle product which is sort of corporate speak for we sell anything that you would use to sell store process or consume the plant uh so anything from functional glass rolling papers vaporizer hardware pre-rolled cones and child resistant packaging is a big line for us and so our customers range uh a significant uh but certainly not even close to the majority of our customers are licensed cannabis businesses in states where cannabis is legal and then for other products we sell to to smoke shops gift shops uh you know sometimes called head shops and then we have a substantial direct to consumer arm so you know we don't touch the plant other than we do sell some hemp derived cpv products and we've got a whole set of compliance procedures and rules around which products we carry and and the documentation around those but our our connection is is as an ancillary business so you know the issues i think get really tricky for someone in katrina's position when when dealing with us because undoubtedly there's cannabis money flowing through our business but our business is unambiguous or at least from my perspective unambiguously compliant with federal law okay and so green lane as i mentioned is a public company listed on the nasdaq um you became you went public in 2019. and tell us what uh tell us a little bit about the cannabis related and and disclosure discussions that came up with getting listed if you will sure yeah and and so i guess maybe first point i'd make on that just just because it might be of interest to this audience is you know we didn't really have those discussions with the sec i think from their perspective they're concerned with uh with proper disclosure under the law and they're not here to judge uh the business so much as to whether your disclosures are are accurate uh so where the discussions come up with are are the banks as katrina alluded to uh and the uh and the exchange as well and so for us the big question was okay given the products you carry what about the controlled substances uh act prohibition on paraphernalia and where we came out is is and there's a risk factor that anyone can look up and read uh is an explanation of why we're in compliance with the law which essentially uh comes down to uh the categorization of the types of products we sell and then for products that do fall into you know the statutory definition of paraphernalia a system of restrictions so those are only sold in states where it's legal and therefore subject to the state exemption in that same statute um do you continue even with the loosening that andrew has talked about and that katrina talked about do you continue to get questions from bankers or other vendors to you about your business and what are their concerns and how do you overcome them how does a business in this business a cannabis adjacent business as you call it um get financing get customers who are going to be accepting what you acknowledges some funds from cannabis that are flowing through yeah it's a it's a great question so i think you know i would break the questions we get and the issues we get into sort of two categories one is the the legal compliance or strict legal compliance and the other is is more of the reputational type questions i think there's absolutely a concern amongst some service providers uh and so you know the first question we get is the same one we got from the exchange which is okay demonstrate to me that your compliance with compliant with federal law and so whether that's a bank or a or someone who provides a major system for us or insurance company will have these discussions you know and we'll share all our policies and procedures what products are sold where when it comes to cbd here's the licenses for our vendors here's the certificates of analysis for every product here's the matrix of uh you know here's the states and counties in which we don't sell products x y and z um and then there's sort of a larger issue for some of them which it you know and and for some people i should say that that conversation will get them comfortable right if if they're going to uh be willing to have some exposure to the space and and i would argue they should given the opportunity here uh they'll get comfortable once they understand our compliance there there is another set of of folks who probably just won't get comfortable and it's it's understandable although regrettable um you know and there's an education process i think that that has to go on as well about what the industry is and what the industry is and for people who aren't in the space there might be a lot of misconceptions uh you know if their experience was you know from their college days let's let's say right and the industry's grown up a lot i mean you can you can see what these companies are reporting in their earnings the type of management the type of leadership um and i think people uh investors should should draw some comfort from that um certainly for us you know having a nasdaq listing is helpful in that in that conversation it's okay banks vetted you the exchange vetted you you maintain that listing uh so it gives us a leg up but just the same you know uh banks and and vendors can be fickle and it's uh subject to the whims or or risk tolerances you know sometimes very small of of some of these more conservative institutions and it's just uh a hurdle or a tax that you know you have to be willing to uh deal with to capitalize on the growth of the industry okay one last question for you um yesterday there was a stock deal announced for a a multi-state operator um uh two large dispensary operations if you will combining does that give you any encouragement that financial restrictions are loosening or that investment appetite is increasing or since it was an all stock deal is that just for the proof that you really can't move too much cash around in business yet uh so investor appetite is definitely increasing i think the regulatory side of it is probably only a small piece of that to be realistic i think as andrew pointed out it's it's been slow going in terms of banking reform uh but but people's risk tolerance uh you know is inverse or is proportional to the opportunity uh and so some people may be more willing to bear it uh given the opportunity i i don't find that for the larger corporation you can look back the last two years and see some massive deals in the space some of which fell apart for for non-regulatory reasons um i don't take it uh as any concern the stock is any indication of uh difficulty moving money around there's a lot of appetite amongst family offices private investors certainly not institutions much to finance katrina nodding vigorously i i can tell you from personal experience people are looking to finance these deals absolutely um so it's a good sign we we love to see it i think the consolidation is going to continue but i don't know how much i would tie it towards the the regulatory developments okay that's that's a fair point um you know i always consider the regulatory first given that i my job is to defend people don't get in trouble but i'm glad there are other business uh business priorities um besides that um okay let me let me we have a couple questions from the audience um so let me um ask a few of those in in our 10 minutes and please do send more audience uh we're watching the watching the chat box andrew a helpful question what help do you need from the financial industry community what what what can they do from for the ncia who should they be talking to what needs to be done you know i appreciate you asking that question jody um you know i think that the biggest thing the financial industry can do is to help us make the economic case um on january 20th we're going to have a new president and we're likely going to be in a recession and the country is going to need tax revenue and the job creation that our industry creates and has generated uh we did you know 12 billion in in business in 2019 um and we're poised to do 15 billion in sales in 2020 uh but we really need to make that case to the federal government that we can create jobs we can generate tax revenue uh that would be the biggest help i think okay if i could just comment yes please it would be great if any short of legalization if we have some some sort of um legislative framework that sort that provides cover for firms like milwaukee not just banks wealth management firms too would you have been covered by the safe banking act katrina would i have have fit in there i don't think so maybe there are competing versions around but it was my understanding that it focused mainly on banks and perhaps credit unions too yep i think i think that's right um and i think that you know that's that who that's who has the loudest voice in the biggest right so if you think of it from an aml perspective though it's we're all subject to the same sort of pillars of aml compliance and in my mind if there's going to be cover it should be cover for banks credit unions money transmitters casinos and firms like mine because for a while now um the the cannabis direct businesses have been sort of trying to find any port in a storm especially smaller businesses to inject their cash into the system so they're going to casinos they're going to mom and pop check cashers and it just creates an awful lot of risk so soapbox put away now yeah and if i if i could agree with katrina for a second i think i think that's exactly right and you know the protection should be obviously the easiest way to solve it is just to legalize marijuana but even abstinent that the protection needs to be broader because this money is everywhere in the system you can't if you know you talked about the substantial revenue test before i get that question all the time what percentage of your money comes from cannabis businesses and i find it to be somewhat of a i mean i understand the reason for it because you have to find a way to gauge the risk but at the same time it's what's okay 10 5 20 is that question being asked of a plumber in california or an electrician in california and so if it's just targeted narrow protection it doesn't really solve the issue couldn't agree more with katrina thank you um so [Music] uh compliance um a lot of a lot of the questions either by regulators or by banks um nd and the types of systems that um the national cannabis industry associate uh the self-regulatory organization andrew and doug that you both work for had to do with making sure that whatever federal business has done whatever financial transactions are done is uh with state compliant marijuana businesses that's what gets the protection under all sorts of um all sorts of laws and public policy pronouncements how do you how do you do that compliance so let me start with with katrina when you do have some cannabis revenue or you have um some some investors wealth that you're managing that comes from cannabis how do you make sure that the the wealth the revenue is coming from state compliant cannabis businesses what do you do is it just a certification is it you hire a due diligence company how does it work sure i mean and there's a there's a cottage industry for this right um as i mentioned before we're very we're very conservative and so we to the to that ring fencing issue i mentioned before we're mostly focused on actually unfortunately keeping those proceeds out even if it is legal at the state level hemp is an interesting situation and we could have a whole day-long discussion on it um but there there's a stronger framework and just as an aside the hemp space is fascinating to me because for years and years and years nobody looked at it none of them had trouble getting services or you would have and all of a sudden it's in the spotlight because of this broader set of policy issues around around cannabis so i think for us cbd hemp there's more flexibility there but unfortunately we're pretty conservative okay anybody else have done tell us about compliance on your side please yeah so you know we we want to know that we're doing we're obviously not a financial institution not subject to to aml requirements other than you know form 8300 and these sorts of things um but we only want to do business with compliant businesses because it can give us comfort to our investors into the outside world and banks and vendors so you know i think the first and foremost is verification of state licensure right there's a state licensing system and a varying robustness in different states but every every company we do business uh in the cannabis industry is licensed we have verification of their license on file and if we don't we can't do business with them sale just won't go through the system um and so you can piggyback on the work state regulators do and then the other thing we do which is sort of chicken or the egg is we don't deal in hard currency so our view is okay if someone's been accepted by a bank there's another level of diligence for us us to rely on um which is why something like safe banking would be so huge for us because it would open up the pool of potential customers do we have trouble getting an account no um but man there's thousands of customers out there that do and i guess the last thing i'd say is you know there's a narrative out there that cannabis businesses are unbanked i think probably the right word to use is underbanked um they're out there and you see all these deals publicly announced these companies have bank accounts what they can't get is the full degree of financial services and then where you really have the safety issues um and the real cash flowing is generally with the smaller businesses like katrina mentioned well we have just one minute left um i'll ask any of you or hope and encouragement um that finance and cannabis ventures is uh is possible um and uh and then we'll sign off um andrew any last word you know look i think we're gonna have a big champion in kamala harris um in ovp so i think that's a very good sign and as i said earlier i think uh the patumi chairmanship is a very good sign the other piece uh is barbara lee um who has been a co-sponsor in the more act and uh could potentially take uh senator harris's seat if gavin newsom appoints her so it's a very positive signs happening okay so politics is something to watch last last word i'm just worried that when it all gets resolved i'm not going to have anything interesting to talk to my family about it because the holidays and my board of directors loves this stuff no in all seriousness i i do think we'll get there eventually to to the earlier point the revenue stream is just going to bring about change okay and doug in 30 seconds you can have one last comment um you know i think andrew said it all or maybe what i want to use my time to support andrew and ncia and all the organizations that are pushing for this change marijuana policy project uh and others that are really making a difference as katrina said and as we've talked here there's the interest in this area is just growing and growing um and while you know people may view it as inevitable that there's banking reform tax reform legalization uh it's not inevitable without support for those organizations so please help if you can all right well well said everybody i want to thank the the large audience that we've had today i hope it's been interesting i'm sorry if there were any audio difficulties but i have the finest panelists and i know you heard them well that was more important so thank you all for joining and have a good day and keep a watch to this space you