The creation of New York’s conditional adult-use retail dispensary license has made headlines. Although New York plans to issue only 50-100 of this new license type, the license type and its underlying rules and regulations is incredibly significant. Why?
First, because the OCM and CCB have issued actual rules and regulations that will apply to a specific license type. The rules and regulations are comprehensive and provide a clear template for rules and regulations for the other license types included in the MRTA. The promulgation of conditional adult-use retail dispensary rules and regulations are a clear indicator that all of the other adult-use rules and regulations are coming soon.
Second, these rules and regulations provide a roadmap for New York’s social equity program, particularly with respect to retail dispensary licenses. Many of the rules and regulations track the Social Equity Fund that we recently wrote about, again highlighting that the CCB and OCM are actively coordinating the interplay between the various aspects of the adult-use cannabis program.
But enough of about the big picture. With any rules and regulations, the devil is in the details and there are a lot of details to unpack here.
Who is eligible for a