​I work for a bank located in Missouri, who has recently passed medical marijuana. Our bank's current stance is that we will only bank CBD businesses that follow and obey the Farm Bill Act and the Missouri laws.

However we are wanting to get disclosures set for all of our commercial customers stating that they are following all State and Federal laws regarding CBD and are not MRBs when they open their accounts, as well as an annual certification form like the annual MSB certification form.

We are also looking for a Commercial Loan certification form that our customers would not rent the space or facilities, or provide services to a MRB.

The standpoint we are taking is that we (as the bank) don't have the resources needed to certify our customers are following the laws (besides the appropriate licenses, paperwork, and monitoring system) and can't drill down into their vendors or suppliers, so much like CDD/EDD we want to use this certification form to take our customer's word for it. If they sell CBD we will add the MRB risk to them in Verafin in order to make sure we are monitoring them for any anomalies in that business's activity.

Would anyone care to share any details regarding a certification form or something similar that they use?

Thanks

if you are looking for a certification form for a loan, i'd suggest getting your legal counsel to draft it

Thanks, that was our thought as well, but wanted to see what others were using.