Any opinions on vape shops? Do you feel this business is riskier or different than a convenience store that sells vape? (Texas) The owners are not from the area and young. 21 and 19 … legal "vaping" age is 21

Interesting question. Do you know what kind of "vape" they are selling? Texas has some interesting laws around CBD. If it is hemp derived and below the .3% THC threshold then it is legal. CBD with a higher THC content, up to .5%, is legal with a medical card. If their vapes are CBD related, then you'll want to do due diligence around them, and monitor to make sure it's not a front for illicit activity. But, because hemp is legal, no additional filing requirements are in place.

If on the other hand, the vapes are not CBD related, and say just run of the mill, fruit flavored stuff, then you'd treat them the same as if you had a store that sold beer or cigarettes (which has a minimum age requirement).

They estimate 10% of the sales would be CBD related, and the customer stated they contain zero THC.

We take it on a case-by-case basis. Take into consideration their product offerings, transaction volumes, account performance, etc and formulate risk based on that. If you have concerns then start asking questions - do a site visit, ask for inventory list, manufacturer lab analysis on CBD products, sales reports, procedures for verifying age, etc.

Always helps for the account officer or branch manager to develop a good relationship with those kinds of customers so they keep open lines of communication. If their product offerings change to where they start offering THC then you want them to be proactive about letting you know.

You might also want to research Delta 8, which is a hemp product that is just a tiny chemical bit different than THC, but does produce a high. But because it's derived from hemp, and isn't THC, it's legal. There was an interesting story on it in the New York Times, and I figure it's going to the new big thing. The chemists and growers are ahead of the law, and it will take the law a while to catch up. Also -- you can vape Delta 8.