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#2216455 - 06/25/19 09:56 PM Our State's New "Cannabis Regulation and Tax Act"
CountryBanker Online
Gold Star
Joined: Mar 2013
Posts: 266
Northern IL
One of the interesting provisions in this bill will allow persons eligible for medical marijuana (and over 21) to grow up to 5 plants at their primary residence. Given that this is still a federally illegal act, and maybe your Board has taken the stance that the bank cannot provide banking services to Marijuana-Related Businesses (MRBs), will you be exiting any customers who are found through due diligence to be growing their own marijuana?

Or might you try to keep the relationship, since the growing is allowed and legal in Illinois, and begin to file Marijuana-related SARs on such customers?

On a similar but related question, what are you doing if you find that a customer is a dispensary employee?
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Opinions or attitudes are mine, not those of my employer.

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#2230016 - 01/31/20 03:50 PM Re: Our State's New "Cannabis Regulation and Tax Act" CountryBanker
CountryBanker Online
Gold Star
Joined: Mar 2013
Posts: 266
Northern IL
OK, so I can understand why there's reluctance to comment. Let's try a different discussion topic.
Tomorrow is Feb 1.
Do you have your marijuana banking policy approved by the board and in place?
Is it a standalone policy, or is it part of the BSA Policy?

Still a work in progress here, except that the board has said 'No' to banking true marijuana businesses.
_________________________
Opinions or attitudes are mine, not those of my employer.

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