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#2242394 - 09/14/20 05:33 PM CBD Products
Banker Forever Offline
New Poster
Joined: Jun 2019
Posts: 24
Does anyone have a checklist or set of questions you ask your business customers, such as a pharmacy, grocery store, or convenience store about what types of CBD or hemp products they sell? In my state, no SAR is required as long as the products being sold do not violate FDA rules.

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#2242405 - 09/14/20 07:03 PM Re: CBD Products Banker Forever
P*Q Offline

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P*Q
Joined: May 2001
Posts: 8,458
Somewhere
CBD/HEMP PRODUCTS

Does the business sell any products containing CBD (i.e. oils) or HEMP (typically located in stores, around the register area).  Yes  No

If yes, what is the sales volume? How much does the business order and how often?_________________

Where do they obtain the products from? _________________________________________

Do any make medicinal claims?  Yes  No

What percentage of overall store revenue/sales are from these products? __________________________

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#2242409 - 09/14/20 07:15 PM Re: CBD Products P*Q
Banker Forever Offline
New Poster
Joined: Jun 2019
Posts: 24
Thank you

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#2242566 - 09/16/20 09:04 PM Re: CBD Products Banker Forever
Goodland Offline
Junior Member
Joined: Nov 2015
Posts: 35
According to the FDA publication in Aug 2020, how are you dealing with the sale of CBDs in regards to the Food Drug & Cosmetics Act?
https://www.fda.gov/news-events/pub...ts-including-cannabidiol-cbd#legaltosell

See questions 8-10.

Trying to figure this one out...how do we get around the "Dietary Supplement" or "Food Additive" for CBD Gummies?

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#2242576 - 09/16/20 09:36 PM Re: CBD Products Banker Forever
BrianC Offline
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BrianC
Joined: Nov 2004
Posts: 6,685
Illinois
Quote
how do we get around the "Dietary Supplement" or "Food Additive" for CBD Gummies?


You don't.

Consistent with FinCEN's guidance on hemp related businesses, some institutions are taking a risk-based approach to develop questionnaires to ask businesses to attest to certain things, such as not selling products with over 0.3% of THC levels, not selling any products that don't meet FDA standard (and then listing examples such as edibles) and then having the conversation from there.

You either decide to accept the risk and continue to bank the customer (and evaluate filing SARs based on their sale of gummies) or they stop selling those products, or your terminate the relationship. Those are really the three choices you have. You due diligence on these customer may also include reviewing the "warning letters" the FDA sends out to businesses selling illegal products to see if your customer is on that list as that may have a bearing on what steps you take.
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