Last week the Marijuana Regulatory Agency (MRA) released the long-awaited updated MMFLA revised Medical Marijuana Application Forms and requirements for Prequalification. At first run through while preparing a set of applications we notice two major changes to the MMFLA requirements and disclosures.
Previously applicants were designated as an Entity/Individual who would apply with an EIPP and as a Supplemental Entity/Individual who would apply with a SAPP. MRA has adopted new designations for applicants and those required to provide disclosures, most notably creating a new application for an applicant applying as a Sole Proprietor:
AEPA – APPLICANT ENTITY PREQUALIFICATION APPLICATION (common)
SPPA – SOLE PROPRIETOR PREQUALIFICATION APPLICATION (uncommon)
SEPA – SUPPLEMENTAL ENTITY PREQUALIFICATION APPLICATION
SIPA – SUPPLEMENTAL INDIVIDUAL PREQUALIFICATION APPLICATION
The first and most notable change to the requirements is that the scope of financial disclosure has been reduced from 36 months of statements down to 12 months. Under the old rules and applications, all applicants (see new definitions) were required to submit statements for all personal financial accounts (bank, investment, retirement, etc.) that were open during the previous 36 months. The new MRA rules only require 12 months. This will be a great relief to anyone considering the licensure process.
Second, and similarly important, Real Property documentation is now only required for property that is being used to meet minimum capitalization. Thus, if you own 50 rental houses, 2 strip malls and 6 commercial buildings, for example, documentation is only necessary for those being considered for minimum capitalization. All Real Property must still be identified on the application form, but documentation is only required for capitalization purposes.
As we continue to work with these new medical marijuana application forms there are bound to be other changes and updates that we will highlight and bring to your attention.
If you have any questions just give us a call, we’d be happy to help talk you through these changes.