How To Sign Arkansas Banking Form

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good afternoon everybody I hope everyone's doing well thank you for being here mega conference it's always a great time to get together with fellow bankers and learn what's what's happening in our industry so again thank you for being here my name is Rob Robinson I'm the community president of Simmons bank in El Dorado and I'm a senior credit officer for Simmons as well and I'm your Arkansas Bankers Association chairman for the year again thank you for being here hope you're enjoying your lunch please continue we're going to start the panel but I think he's no one's gonna mind if y'all keep eating while you do it so we're gonna move keep moving because I know we've got some this afternoon we've got a lot of things going on I want to get you all out of here on time with with without further ado I want to introduce the moderator of our help banking panel today Kevin Hart and it's not the comedian in fact it's my stand-up mic it's about the exact antithesis of Kevin Hart and I'm sure he'll sprinkle in a few Kevin Hart references as he leads the panel today Kevin is the CEO of green check verified since 2015 he has focused on solving one of the biggest problems in the cannabis industry cannabis he formed a team of former federal examiner's bsa/aml compliance experts and technologist to tackle these unique banking challenges the team then developed a solution for banking cannabis that is purpose-built to work within the banking system and not around it the green check platform was formally launched in January 2019 is now running compliance programs in multiple states and growing I'm sure we're going to hear a lot about that today mr. Hart is joined by two panelists daniel beck vice president and general counsel for simmons bank and dan martini vice president president of congressional relations and political affairs for the American Bankers dan thanks for making all the way down from DC and I hope you found it cooler than when you left it we're really looking forward to the discussion today so please help me welcome the hint panel so good afternoon everybody again my name is Kevin Hart I already got a great warm introduction so you don't need any more information about us I will just say that green check is active and live in Woodstock moment in nine different states right now including large publicly traded financial institutions again we're purpose-built to work within the banking industry for banking cannabis programs so there are guidelines from Vinson etc as to how to do it the questions of can how and why should I are always on top of mind for everybody in the banking industry so that is what we set out to do so I'm really excited to be able to moderate this panel had a pleasure of meeting these two gentlemen over the phone so it's great to be able to shake their hands in person today I'm gonna let them each introduce themselves and then we'll jump into the program so Daniel all right hi my name is Daniel Beck I'm senior counsel with Simmons Bank I've worked in the Little Rock for about eleven years now I practice in private practice before joining Simmons a little more than a year ago I know a lot of you as some of you new faces but I'm happy to be here and looking forward to this discussion afternoon everyone again den martini with the American Bankers Association I've been with ABA for about two years now and I just wanted to thank you all for having me down here whether is much nicer so I appreciate that I am one of the six or seven congressional relations folks that are the face of ABA through the halls of Congress so my job is possible because of your support so thank you very much and today's discussion so the you know the outline of the program on that work as you notice we don't have powerpoints we don't have the pitch decks up here we're here to talk have questions have conversations and we're hoping that we will get a lot of questions at the tail end of this but what the agenda is we're really going to tackle this from the federal level what's going on with the farm bill what's the difference between hemp cannabis CBD THC some of those questions you need to be understand and then really what's going on here on the ground in Arkansas so starting at the top of the funnel and kind of drill it down hopefully we'll be able to address some high-level questions and concerns we're here to sprinkle in some heavy detail as part of this but since the 2018 passage of the hemp farm bill from my seat and from what we see on a nationwide basis it can delay has done nothing but cause a lot of confusion a massive amount of confusion so much so and I was talking a moment ago to Rob well the interesting things is that we've actually seen people who were we call them kin of curious people are on the sidelines trying to figure out how to enter this into this industry they actually have moved away from hemp and actually have gone more towards pure marijuana banking highly regulated easier to monitor not regulated em from a banking perspective harder to monitor and then recently with the House action when they voted on the safe banking act you know that popped up a whole new wave of questions and different approaches and ideas so again starting at the top we're gonna talk about you know the recent action that's gone on in Washington we're a safe banking Knack seems to be getting momentum certainly in the house we'll kick around what our opinions are and what we hear what's happening on the Senate what the outcome of that looks like and that will move through the platform so you know Dan you just flew in from Washington I'm sure the ticker caves are running hot hot and heavy yesterday so what's your what's your take on where we are with safe banking act and what is your crystal ball look like sure thanks Kevin so as some of you may know the safe Banking Act passed the House with broad bipartisan support about two weeks ago now the final vote was 321 to 103 including 91 Republicans congressman Hill and Congressman Womack from the delegation also supported passage so that's a huge step that's the first major vote on cannabis related policy we've seen in the in house or in Congress as a whole so now it's kicked over to the Senate so where does that leave this piece of legislation well Senator Crapo chairman of the Banking Committee has recently stated that he intends to take up something on cannabis banking this fall what that something may be is likely a variation on the safe Banking Act so senator Gardner from Colorado has his own version of the bill along with Senator Warren I believe that is where the Banking Committee is going to start in addition to some of the issues covered in the safe Banking Act along with the hemp provision and operation chunk Boyd an anti operation choke point ledges language senator Crapo has indicated his concerns on legacy cash how to do deal with interstate banking and also some of the potency issues between hemp and pot handful or THC are hemp with higher levels of THC so I think what we'll see from my opinion and from what I've heard is probably a hearing towards the end of this month on the issue and then potentially a markup which would be the first markup in over a year and the Senate Banking Committee likely around the November Thanksgiving time like that said a lot of things are going on in Washington DC right now so the entire process could be derailed by the events of the day and its seemingly a new issue so cautiously optimistic we get something in through the Senate this fall but again we'll have to wait and see well I think it's good to just kind of clarify what the issues are in relation to him you know one hemp is different from marijuana obviously after 2018 farm bill a hemp was taken out of the controlled substance act so it's not illegal and they're waiting on federal regulations to come up and so there's still a lot of him going around so what does that mean well in 2014 there's an there's a bill that allowed pilot programs in several different states Arkansas including some of the states around Arkansas and others adopted the pilot programs and this pilot program said that you on a limited basis you could start research including the research with marketing so this is run through the the plan board in Arkansas so over the summer there have been people in Arkansas who are licensed you get to grow and sell him a lot of times they'll sell the different pieces of the hemp to producers those producers can manufacture the different Hampton etc there are different pieces of the hemp plant flowers and seeds that are going to be regulated tightly and then other things that are not going to be as regulated so if you came across somebody selling a hem t-shirt that doesn't necessarily mean that they needed to license to sell an t-shirt if you're going to be making a loan to somebody who grows and well you've got a different set of issues and so at the federal level one with the safe banking act I think they're trying to make bankers understand that yes him in fact is different from marijuana and it is legal and they're trying to push new regulations or at least get the regulator's get some guidance to banks about this is the best course of action when you have a ham customer and this is different from the fencin guidance related to marijuana it's a totally separate issue and in the most recent farm bill that I think you had brought up there's an issue with CBD that's derived from him that the we're having issues with or not we but people were trying to sell CBD products are having issues with so the main issue is when can CBD which is a derivative of hemp can be sold if you went to Kroger today you'd find or Dillard's or other places you find a CBD area that's legal because of the FDA is not regulating something like a lotion but if you see you know the best new improved CBD candy bar well you might want to watch out and so trying to get clarification on that but for banking purposes if you're going to have ham customers it's about what's the appropriate risk and understanding what the risk is and how to handle it you know one of the things that the lack of clarity that that we see and we hear and I'd love to get your opinion on this and you know you actually work for a financial institution and you get to talk to so many more is you know I'm sure everybody in the room has heard the acronym of FOMO fo mo it's called fear of missing out and there are a lot of F eyes that are again k in a curious hemp curious on the sidelines and they see this explosive market occurring on either side doesn't matter if it's the hemp based or the marijuana based and they see all this cash in this opportunity for low-cost deposit dollars and the the lack of regulations or clarity and or the strict guidance from FinCEN you know depend on how you look at it there is a lot of FOMO you know going on out there where people are trying to figure out can I do this how do I do it is this worthwhile should I should I jump in you know what sort of feedback and you know either at an institutional level or at an ash are you all hearing well let's take where is a hands what financial institutions Colonel II have customers that sell him okay we got some people we're growing growing okay so um I've seen concerns before about dipping their toes into the water and and I think you just have to be careful and you just have to make your appropriate risk you know if we if you're gonna try to make a loan to a grower you've got to understand that there's a risk that when they grow the the hemp the THC level could go above 0.3% if that happens you've got a hot crop while you're hot crop is gonna be destroyed so if you're making a loan based off of the resale of that him exclusively well that's a high-risk loan if you've got an account with somebody doing it and you know if you you know a Kroger or a dealers that sells CBD it's not gonna be as high if you have a standalone CBD and hemp shop selling all sorts of kinds of things you know whether you have an account with him or whether you have loans with them and you're gonna want to inquire to some additional information about what the appropriate risk of this customer is from a sort of a broader national perspective I've seen and heard a lot of frustration about a lack of guidance from USDA as part of the farm bill in 2018 I don't believe we've mentioned it yet but USDA is required to release regulations they were sent over to the White House for finalization a couple weeks ago and we're anticipating end of this month they'll be released but once they're released there's still the implementation aspect and that gets into the commodity insurance and crop insurance as well and how that will be regulated for hemp so I think there are folks that are very interested in getting involved but the the uncertainty and the lack of clarity and regular it's just preventing them from doing so at this time and from my opinion I don't see that getting any better at least in the near future do you see the safe banking act and of itself as they're talking about it now and there are some carve outs and that in the head for hem particularly you know having you know a facilitative impact for people earlier than anything that may happen out of the Senate not necessarily safe banking Act is not law it's only passed the house and as we've all learned from watching schoolhouse rocks or social studies class over the years if I'm a bill just sitting on Capitol Hill it still needs to pass the Senate and be signed by the president so the president's still kind of a wild card in this situation he's her personal reasons he's opposed to various substances and he's had some family history there so I don't know if he's gonna sign the safe Banking Act into law he did sign the 20:18 farm bill which had some provisions in there related to hemp as we've discussed but this is a broader package so the safe Banking Act does not do anything in its current form to to I think get people off of the sidelines yeah and I think even if it was it passed it's gonna make it a little bit more confusing you know I have to remind people it's legal it's legal it's legal um and you know except for the issue with CBD and so the most safe banking act is going to do at least when it comes to hemp is to say no we really mean it and so you know what you know the federal regulators if the safety Banking Act passed as it currently stands specific to him it would say what we're gonna do the best practices when it comes about the Hamptons like okay well how you do how do you do that because you don't even have add the regulations related to the 2018 farm bill instituted and so it'd be hard for banking regulators to come up with guidance on top of that and I will you know one thing that we haven't raised it's right now the pilot programs are just in places where the states to pass them around so Arkansas passed the pilot program and his acting Oklahoma passed the pilot program and it's acting Texas did not pass a pilot program they've passed him reg ulation but they're waiting on the 2018 guidelines to come through once the 2018 guidelines come through states are gonna have to go back to the USDA and say approve our program again so Arkansas will have to do it too so we may have a bit of variation in what our current and regulations are in regard to him and after they funk you know hopefully 2019 don't actually have regulations related to 2018 farm bill but we'll see okay I mean from a personal opinion and you know working with lobbyists at the national level when we look at the safe Banking Act I think there's a couple of things one you know the the the rule says that you will be allowed to bank there's not a period at the end of that sentence pardon me it's a comma in the comma says provided you follow all the rules and regulations so Washington cannot help itself it never has helped itself this isn't a political statement it's just we can expect more rules and regulations you know coming out of that so the worlds and regulations as they stand today will become a little bit more complex you know for the banking industry when that comes out I think further to with the the scheduling or the D scheduling and the classification of this Treasury Department really doesn't care what FDA and he USDA says they're concerned about money and you know good money going into the banking system and bad money staying out so you know this is never just going to be a green light that just says okay everybody go ahead bank do what you want even if you're following the rules and regulations because you know the illicit market in the u.s. is about five to eight times greater than the illicit market even after this this the the farm bill came on and a lot of that has to do with the derivative product so everybody's heard about Bay plung in the bait crisis etc you know that's throwing a big big wrinkle into you know how hemp is now possibly gonna be banked so you know what do you guys see or hear as it relates to that aspect of the product safety I mean for our purposes we can't really make a determination we don't know what's gonna have to happen with vaping regulation and it again just goes to your customer and knowing your customer are you doing business with a CBD standalone shop that you know could have other issues do you have a CBD shop where you know the owner is also an owner of a marijuana company and you know those types of issues are gonna have to be analyzed when you say yeah we're gonna open them accounts for somebody with the CBD shop or extend alone etc and so vaping you know I I don't know what's gonna happen and but you just have to keep in mind if you're gonna go forward the different type of risk that that can be created with a different type of clientele and to sort of echo that the ABA for our position we don't take a stand on the legalization of marijuana I think the vape issue ultimately is in that realm from a purely hemp specific point of view I think as there are efforts to potentially regulate faith and Bey products you'll see enough of a reaction from certain senators representatives certain committees to carve out hemp I mean there's a reason why it's been there was a pilot program in 14 there was further guidance in 18 and now it was included in the safe banking act to sort of get it over the finish line through the house so I think the vaping issues a larger problem related to sort of the cannabis conversation as a whole but from the hemp this specific thing or specific perspective I don't think it's something about okay so you know when you know as an fi and they're looking at some of these businesses and they have a license their grower they're recognized you know farm or you know hemp-based business you know one of the things that you know they really need to be able to do is understand what products are being sold so that they're not you know mixing money or you know and you know mixing product etc you know what do you what are your thoughts as it relates to you know structuring programs you know from an account onboarding a transaction monitoring and then ultimately what sort of reporting requirements you know are you anticipating might come out of this you know we don't know right you know they're they're crafting this language as we speak and you know we're all trying to look through again our crystal ball and understand what the future might look like but do you have any indication of you know where that might go well well I was gonna say you know I since I don't know what's gonna happen I have to look at what we have right now and what we have right now is what do you what do you look at ahem customer when they come online and I've touched upon several different issues and you just have to say hey at what level do we have to raise our inspection into the customer you know you you himp is not gonna be standalone in the fact that you're gonna have many people who are doing marijuana business on top of that and you know I'll give you an example so for Oklahoma they've got a hemp program during the pilot program but as of July the the marijuana laws in Oklahoma are different from Arkansas essentially it's the Wild West it's only medical marijuana but you know Arkansas you have five cultivators and 32 dispensaries in Oklahoma you had I think something like 3,500 cultivators in about 1500 dispensaries and by the way you get to grow your own in Oklahoma more now morning yeah okay so when you you get kind of the the cross customer and issue when you take different people on and and depending on how you develop your BSA system and the the type of due diligence your system can can check and hit those people who are licensed I mean these people get like it's weird to think if it's if it's drug like any other drug you don't usually have cocaine dealers registering themselves with the states and and so that information is available and so when you have a client come in is your system going to tag and say oh yeah this person also has a marijuana business or they have some you know company etc and so you you have to think about that on the front end because even if you're not doing business with him customers you they're gonna start coming in and their employees are gonna start coming in and it's better to have a plan of action on the front end then be huddling up every single time you know you be SA sinds enough you know large you that how this is going and we've had an issue so that's about all you can do is deal with the risk that you have in front of you and let ban worry about the future and I mean it's it's gonna take some time to figure out what USDA does then there's a potential AML BSA legislation that might overhaul that program as well so in change reporting requirements there's so I'd say just have a plan of attack do your due diligence and just keep in touch so we can provide you with some updates I'm one of these new regulations will go into effect give you another common scenario if somebody does come in and say hey I've got a marijuana business where you'd be Banking with me no okay well I've also got a him business where you do banking with me maybe you know I'll let you do your own analysis but somebody has come to you and asked you to be participate in money services related to a drug now you don't even have to look at the fence and guidance to address that issue you just know somebody a has has come to you as and you know funnel money related to drugs well be in communication with your BSA departments so I'm sure a lot of folks in the audience can relate to this next statement and you don't have to raise your hand but you know the the sheer wealth that this these industries McCallum industries are purporting to you know generate has a lot of your you know more valuable long-term clients making investments in the in this industry or maybe even getting into this industry in terms of financing it could be to a landlord facility could be its releasing land it could be you know they just opened up a dispensary and their financial backers so one of the things and we talk about legacy cash so this is a kind of a multi-part question there's no way to untangle this mess so I apologize that sometimes the questions themselves seem confusing but you have long term account holders that have entered into this industry knowingly but may not have disclosed that to you know their their bank the bank finds out so account retention is actually something that we get a lot of enquiries about and then we also brought up legacy cash from some of these businesses so again just from an opinion standpoint because none of us are lawyers and none of us sir what are you guys is a lawyer I'm sorry I apologize I'm not a lawyer attorney Joe but damn and Dan at law yeah Dan squared Dan in stereo but Daniel and Dan so you know what do you what are your thoughts as it relates that we're not offering legal opinions yeah well you know none none of the opinions of here or Simmons Bank or even my own and I buy that III had to know I had to steal that from a Federal Reserve economists it was a pretty good line but and no and you know I I take the view is you can't have money from an illicit transaction come into the bank and you that's my view and I think that's a straightforward view and it will guide you through a lot of different principles in a lot of different scenarios personal opinion I exercise restraint the projections of all of the the revenue that can be generated in this space it's a lot of it's based on a limited supply right now and we don't know where the regs are finally gonna go so if people start growing if we look at him specifically people start growing more happy well what happens when you have a huge supply of something the price is gonna go down there's reports coming out now about tax revenue in states where marijuana is legal the projections are down so I would just exercise caution as you move into this process and maybe start dipping in at our there jumping in commoditization is as absolutely occurring you know as relates to the price point of the products and it's all the products you know it's you know certain states that were out there further and and have a history of running you know especially Oregon and Washington etc on the cannabis side their price points have dropped so dramatically they're actually pushing really hard to create interstate commerce and we talked about interstate commerce financially but there's also the interstate commerce a product etcetera so what is going to be legal what's not going to be legal and how that all gets structured is is very fascinating so if you one of the things that we've learned in talking to financial institutions is that you you have to be black and white in terms of what your your your stance is on these programs you either have to have a hemp cannabis banking program or you have to say you don't have a hem cannabis banking program to some of the points that you raise that you both raised and so at what level do you do you push that okay so there's Tier one we didn't make this up this is somebody else's definition and it's stuck in the industry there's tier 1 there's plant touching businesses you know their whole businesses derived from something to do with the crop doesn't matter which one it is then there's tier two where you know the vast majority of their revenue is derived from supporting those industries and then there's the tier 3 people you know your utility company the guy who installed the security cameras you know in a dispensary you know how do you look at those those accounts it's you know it's very complicated so you know we'll start down at the far end of the table at the national level and then you know piggyback onto what you said being you know about you can't touch that money you know how does that how do you see that cascading through you know the banking system I think from a policy perspective and then a place to actually get movement on the issue that the tier 3 into a lesser extent tier 2 businesses are really gonna be the driving factor in getting any sort of legislative change a great example with the safe banking act is Congressman Stivers from Ohio got heavily involved in this issue in large part because of his local tier three tier two businesses that are cannabis adjacent businesses so that I think is an argument that a lot of members are latching on to now and I think there's a chance to to really push from that perspective as far as to how you deal with those types of businesses I'll defer to Daniel on that it puts in a lot of strange scenario so if you're in let's say Oklahoma and you're in the Wild West again and and you've got a customer that you know maybe has a mortgage with you has a an account with you and then one day they come to you and they say oh I'd also like the car loan from you and by the way I changed jobs and I work for a dispensary and 100 percent of my income that I just told you about it's from that dispensary well you've got a banking account with him you've got a mortgage what are you gonna do alright gonna terminate that account are you gonna say no we can't take the money on the mortgage those are real situations that I can see arising um you know again my view is the bank cannot take money from an illicit transaction but know that these issues can arise and and you know have your brain trust with the handsome attorney on it and know that dead jokes fell flat geez I won't do that one again you yeah oh yeah I felt that one that hurt um but now that's I figured the brownies would have kicked in by now but those are gummy bears watch out you're up too late but now that's um it's a difficult situation and you know as I was telling Dan we're in this position because you know Congress allowed you know back in 2014 they started saying DOJ you do not have the money to go after marijuana businesses if it's for medical marijuana and that open that created the environment to where somebody can come to a bank and say hey I sold drugs for a living can I have a bank account and can I have a loan and just to add to that real quick from a personal perspective I think the larger conversation ultimately has to go towards D schedule in cannabis I think given with the Cole memo in 2014 which Daniel reference it's it's a year-by-year thing it's tied up in the appropriations process right now and we all know how good Congress is at getting spending bills done on time or at all so I think with that the larger conversation needs to be had there needs to be medical research done on the effects on some of the potency of THC and I think that's again my personal opinion where we're headed because of this uncertainty yasoda scheduling is is interesting I live in Connecticut that's where our company is based and the gentleman who actually wrote the medical cannabis program in the state of Connecticut we're known for a lot of things not a lot of great things I will say you know I do live there but they are recognized as having one of the best defined and best run Medical Marijuana programs and the reason being is the guy who wrote it will publicly tell you he never wanted a dispensary to open but you know people are creative in capitalism thrives and survives and so they actually figured out how to how to do it and get these counts open but one of the things that he did early on and we see this in a couple of other places too and you know it's a somewhat of a harbinger for what may happen in in Washington is he'd be scheduled he was the Commissioner of Department of Consumer Protection which oversees medical marijuana and Kanika and he changed the schedule - schedule - for cannabis and Washington called them up and they said you can't do that and he said well show me where it says I can't and we did so what's what's gonna happen and nothing never happened but what they did what that did do is it did put further regulations on it because it put it into the prescription monitoring program which is something that you know was very important and very much needed because it is a medical program with very strict conditions and it's monitored like any other controlled substance that you would get so there are you know the point of that being that on a state-by-state basis these programs all have their own rules and regulations so if you are at all entertaining you know looking at these programs in any detail highly encourage you to talk to people that are in the industry that's not about me that's not about us there's a lot of people out there and talk to your peers in other states talk to people that have looked at it that have done it there's a lot of what we call cannabis or hemp thank you 1.0 people they jumped in they thought they could do this they saw it as a green rush you know as some people have labeled it from an opportunity and now they're having to close those accounts you know you mentioned Oklahoma there's you know well-known you know Credit Union that jumped in and they're already winding down the entire program because they realized it just didn't work and one of the other things that we see that's really really important as you're considering all this is nobody likes surprises okay boards don't like surprises examiner's don't like surprises they're party vendors don't like surprises talk very openly about what you're going to do and you're gonna get a wide variety opinions you know there are some boards that are just flat-out never gonna happen forget it conversation over what else you have same thing with the examiners and same thing ith third-party vendors could be your corresponding bank or or others so you'd really be surprised as to once you look at it just how complicated the nuances of that actually can get so wonder if you know have you guys ever talked about it internally you don't have to disclose and say pass or you know everywhere ever talk about what internal you know just full-on have banking or cannabis banking programs and you know the complexities if you ever want to do it oh I mean everybody looks at what the complexity is but you know you you end up on square one that it's against the law and that's not changing until it changes and so that you know that ends up being an easy easy decision okay so that's the majority position from what I've heard from most of our membership that has been open enough to talk to me about it so right now nationally in you you all have this access to the same information that anybody else in this room has that you know over 500 different financial institutions report that their banking you know this industry today and you know they filed the the SARS so your peers and counterparts are out there doing it I will also tell you though if you dig into the details of some of those on average twenty five percent of those stars that are filed their termination stars so they either found out they were banking you know some of these industries and they found out because they didn't disclose that when they opened the account you'd be surprised how many yoga massage studios and wellness and plant centers there are there are actually dispensaries or you know hemp operations but that number continues to creep up so more and more people are getting involved with the industry are they doing it properly are they doing it effectively you know that's that's for the examiner's and you know everybody else that's involved with them too to look at can I just jump in real quick open mic 5 500 500 sounds like a big number but if that's just banks alone there's over 6600 banks in the country so even if it's creeping up it's still less than 10% it is but it's been creeping up on an average of 10% every six months so not too long ago was under 300 now it's over 500 and again you know that you know these are the folks that are part of filing one of the three types of SARS related to this industry and you can see again 25 percent our termination SARS I will say just on this point it'll be interesting I think there is a case filed recently in Arkansas that is a dispute disputed contract related to marijuana my opinion has always been a court will kick that out because they're not gonna see a case that disputes an illegal substance so if there's any attorneys in the room that'll be interesting to watch at least we can see how Arkansas courts handle it yeah so we could we could talk about different scenarios etc but you know this is a session for you we've given you a you know good overview of the national and some of the things that are happening here at a state level any questions if you do if you'll just raise your hand we have a runner with a microphone to get to you all right excuse me we get at least one question there we go yeah do you have any more of the brownies I think we got some open open spots that is one of the questions we get all the time and no we don't take one for the team and go ahead and ask the question you were talking about how it's a major difference between of course the hemp industry and the cannabis industry but looking at those regulations and the potential laws that they're that they're considering at the moment do you see that those will fact whatever legislation in the future comes as far as cannabis is concerned and if so how would it affect it I I think it will affect it just because the you know the concentration of THC and the products and that that's the thing that everybody is really focusing on now that point zero three limit you know there are a lot of CBD based products that have heavy THC concentration I was just in California last week and as part of part of our work we're in dispensaries and it's just amazing you know the selection of products that you know people actually are out there manufacturing and selling so you know it's gonna be really interesting because you know as Daniel pointed out you go to clovers you can go to Dillard's and you know those that's very hard when you walk into a facility like that or you know any of the normal you know quick gas stations that Sarah you see those products you know how does that prevent children you know miners you know people from picking up that product and selling it it doesn't and you know so I think that that will become a you know very big sticking point and there's gonna be a lot of arm wrestling on that I also think again this isn't a political statement I think the safe Banking Act is is gonna get stuck I think it's gonna get stuck in the Senate and when it even if it does come out of the Senate and goes back to the house the house certain members of the House have already talking about certain additional things that they want to put it into the bills and you know different earmarks and mostly around the social justice aspect I could speak for firsthand you know knowing in both Connecticut and New Jersey that those two adult bills got got stopped crushed delayed whatever you want to call it again not taking a position on this because of some of those social equity things that were added into it and so both sides both both the House and the Senate have already started talking about that in you know if they're gonna come to any sense of consensus in conclusion and try to you know put ten pounds of sugar in a five-pound bag again with all this and again it's Washington I just think it's gonna get get stuck and that will be unfortunate for everybody I tend to agree with you initially on we're safe is headed but I think just the with the market with the ballot initiatives across the states there's going to be more legislative action moving forward there there has to be I could foresee again my own personal opinion I could force the FDA getting involved on CBD regulation at some point just because if you go to a local store and you pick up two different bottles of the exact same CBD oil one is tar black and the other ones clear so what's the difference I mean I think FDA is gonna probably try to enter that space I don't know a lot of this could change in 2021 as well depending upon how the outcome of the next election goes I think some of the social justice or social equity aspects will come into play not to get to inside the beltway at all with this next statement but the procedurally the SAFE Act was brought up under suspensions so those amendments would be kept out if they go and the Senate passes their own version and they go to conference those amendments could still be kept out it's just more than corralling the votes by speaker Pelosi so I think there's more legislation coming whether it's safe some variation of safe or possible regulations by agencies outside of USDA I think it's anybody's guess right now more brave souls that's it we gotta clap guess guess who guess who's not interested in any of this stop they gonna later you'll clap well no brave souls no we're not when there's no one recording anything in here all right well y'all what's that exactly that's true that's true well thank you Kevin appreciate you making your way here [Applause]