advisory cannabis

greenco is an East Coast cannabis advisory specializing in macro & micro strategy, expansion,

industry research & intelligence, municipal outreach and market mechanics for regulators, stakeholders,

and operators in adult-use and medical marijuana markets.

The ability to communicate effectively in the language of policymakers is essential for eliminating stigma, developing regulations, obtaining licenses, launching new facilities, and maintaining compliant operations.

In 2025's frothiest markets with a focus on the rollout of adult-use in Connecticut, New Jersey, Maryland, Pennsylvania, Delaware, and Ohio: 

• forecasting state-based demand and supply imbalance
• evaluating the price compression timetable
• deciphering cannabis M&A's volatile valuations
• anticipating and mitigating deal breaking delays

levers and catalysts

> Boies: The dismissal of the Boies lawsuit by the Massachusetts District Court was expected, but the goal was always to fail so the case can be appealed, ultimately on up through to the Supreme Court. The appeal to the First Circuit in Boston now has oral arguments set for 12/5/24. The Boies path to victory will be riddled with lots of developments to confuse and excite the space.

This landmark litigation has even been blamed by the DEA as they attempt to drag rescheduling out as long as they can.  The judicial system may move "faster" than the administrative and legislative reform channels, but litigation sure is expensive. 

> Rescheduling: Threats to "reclassification," as rescheduling cannabis to S3 is sometimes being called, are still rumbling, but the ALJ ("Administrative Law Judge") preliminary hearing is scheduled for 12/2/24 with a January expectation date for testimony to actually begin.

Litigation will surely follow with an attempt at an injunction to hold up implementation of the final rule, though a judge may simply reject that on the grounds that the request is without merit.  The most bullish scenarios have a final rule coming late January 2025 with the reasonably bearish pushing that into the Q3'25.

• November 12, 2024 : Comprehensive information about the participants must be submitted
• December 2, 2024 : ALJ preliminary hearing. Designated Participants ("DP") who will provide testimony must come prepared with availability dates regarding their counsel and any witness such they will seek to present at the hearing on the merits.
• January-February 2025 : ALJ evidentiary hearing testimony from Designated Participants
• ALJ will compile all the evidence and make a rescheduling recommendation to the DEA
• DEA will consider, then issue a final rule by publishing it in the Federal Register
• The Final Rule will become effective 30 days after publication (potentially 4/1/25)

> Administrative Shift: New political leadership could greatly impact cannabis reform at the federal level as the administrations transition over the next months. 

All eyes are on the pick of Matt Gaetz for Attorney General as the Department of Justice and the DEA hold most of the cards as the rescheduling timeline painstakingly unfolds. S3 could get back on the fast track very quickly with our without a Gaetz memo.

Upon rescheduling, the jobs report would begin to include the nearly half a million cannabis industry workers and that will be a metric that is very important to the new administration.

There is tremendous interest in how the new administration and Congress will handle bills like the CSRA (Cannabis Administration and Opportunity Act) and potential opportunities for SAFE and the Farm Bill to enjoy lame duck developments. Senate Majority Leader John Thune hasn't warmed up to cannabis despite representing legal Montana, but it isn't expected that he will block the new administration's support of the industry.

January 2025: More realistically, SAFE gets refiled in January as the new Congressional makeup and committees take shape. 

June 2025: The Farm Bill potentially gets across the finish line, closing the intoxicating hemp loophole to coincide with most states passing legislation to do the same.