I will defer to any Colorado-based poster (almost typed "user," but, given the subject ....) who has obtained anything close to official guidance from FinCEN, but I would not be comfortable relying on any splitting of hairs over the differences between marijuana and hemp. I'd contact FinCEN for guidance or accept the burden of following the reporting regimen for MRBs.
If you do contact FinCEN, the BOL community -- particularly those in Colorado -- would appreciate your sharing here what you find out.
John S. Burnett
Professional Compliance Nerd since 1976
Bankers' Threads User #8