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#2181592 - 06/13/18 03:54 PM MRB/Hemp no THC
MinnieM Offline
New Poster
Joined: Jun 2018
Posts: 11
We have a customer that would like to open an account with us. The customer has partnered with a company in CA to manufacture juice which contains hemp. The hemp used in the juice does not contain any THC. We have chosen not to bank MRBs. I'm stuck on this one because none of the guidance discusses hemp with no THC. Has anyone come across this? If so, how did you handle it.

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#2181640 - 06/13/18 06:05 PM Re: MRB/Hemp no THC MinnieM
The OG Zaibatsu Offline
Diamond Poster
The OG Zaibatsu
Joined: Dec 2007
Posts: 1,697
Texas
I don' think you are going to find experts on hemp, cannabis oil, marijuana, THC or CBD on this forum. I suggest you google "is hemp illegal in Texas" and read the articles on the new "Hemp Bill." Here is one article: https://www.freepresshouston.com/legislative-barriers-are-holding-back-texas-hemp-entrepreneurs/
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#2181653 - 06/13/18 06:51 PM Re: MRB/Hemp no THC MinnieM
MinnieM Offline
New Poster
Joined: Jun 2018
Posts: 11
Thanks! These articles are why I'm stuck. They all discuss hemp that contains THC. The hemp being used by our customer is stated (according to environment reports) to contain no THC. We will err on the side of caution and not bank this customer.

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#2181895 - 06/14/18 08:51 PM Re: MRB/Hemp no THC MinnieM
bankerslife Offline
New Poster
Joined: Mar 2018
Posts: 11
I have seen hemp oil now selling at the local superstore so I am assuming they could not sell it if it contained THC. On the flip side, MRB stands for marijuana RELATED business. May want to stay clear of any type of relation. I would think a cousin is still related to you. confused

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#2181898 - 06/14/18 09:37 PM Re: MRB/Hemp no THC MinnieM
RockChucker, CAMS Offline
Diamond Poster
Joined: Jul 2013
Posts: 1,655
The Country
While not an expert in the area of marijuana and hemp, I believe all hemp does have some THC. I am told that what classifies it as hemp is that it has below a certain threshold of THC. Most industry professionals can't tell the difference between a marijuana plant or a hemp plant and even less so the levels of THC which is why unless you have some way to certify it is hemp and not marijuana most banks stay away.
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#2185395 - 07/13/18 08:52 PM Re: MRB/Hemp no THC RockChucker, CAMS
Rangers Fan Offline
Gold Star
Rangers Fan
Joined: Dec 2001
Posts: 345
We are reviewing this one too-You might also hang out on the DEA's website like I have...loads of fun there. It is not listed on the CSA and apparently the DEA dropped a case and didn't pursue to the SCOTUS on it...https://www.deadiversion.usdoj.gov/schedules/index.html (I feel like a pharmacology student reading this stuff!).

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#2209662 - 03/27/19 02:41 PM Re: MRB/Hemp no THC MinnieM
IronP2717 Offline
100 Club
Joined: Feb 2018
Posts: 128
I think this is a good topic to renew. There are potential state changes in the pipeline.

http://www.fox7austin.com/news/local-new...list-on-april-5

https://txdispensaries.com/cbd-in-texas-guide/

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#2219790 - 08/15/19 06:29 PM Re: MRB/Hemp no THC MinnieM
Always In Training Offline
Diamond Poster
Joined: Jul 2006
Posts: 1,111
Where the Green Grass Grows
Another bump.

The FDA has recently spoken on this topic via its Statement of Policy published in late June. The agency indicated that, as of now, it is “currently illegal to put into interstate commerce a food to which CBD has been added, or to market CBD as, or in, a dietary supplement.” The FDA also noted that it is currently working on rules and regulations surrounding CBD, but it’s just going to be some time.

https://www.fda.gov/news-events/fda...committed-sound-science-based-policy-cbd

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#2221861 - 09/18/19 08:52 PM Re: MRB/Hemp no THC MinnieM
jsim913 Offline
Junior Member
Joined: Feb 2019
Posts: 45
Anyone comfortable sharing where they're at on banking CBD? I tried to talk with a store owner down the street and they were reluctant to discuss any details of their banking with me (I'm gathering that everyone around here is still turning these business away). We're still in the planning phase because we're still unclear on a few pieces.

- We'll require extensive documentation up front (what products do they sell, where do they get it, proof of lab testing for those products, no claims of unsubstantiated health benefits, etc) and then regular updating.
- We'll have to review with our various vendors (Visa for debit cards, merchant services, insurance, etc to determine if there are any issues with providing services.
- Everything has to be imported from another state which is one of the kinks for FDA if they're used CBD as a dietary supplement. Hemp oil, which is distinctly different from CBD oil, is fine to get from another state. However, what are the implications of a store selling CBD droppers to put in your water? Obviously they didn't get it from Texas. FDA has a problem with it but the Texas DSHS indicates that it's ok as it's obtained from a state following a USDA approved plan.
- As long as they're under the 0.3% THC level (and no other shady business is going on), there are no SAR implications at this point.

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#2221886 - 09/19/19 02:17 PM Re: MRB/Hemp no THC MinnieM
Valley girl Offline
Gold Star
Joined: Aug 2014
Posts: 341
TX
We have had requests for accounts from hemp related businesses, but we are too small to try to serve MRBs. The NCUA did send out some guidance which has been publicized in the MRB trade organizations. The guidance has been helpful for us. https://www.ncua.gov/regulation-sup...-other-guidance/serving-hemp-businesses.

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