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.


Delaware Lottery Update

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


  • 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.


  • December 2 : ALJ preliminary hearing 
  • January : ALJ hearing testimony from designated participants ("DP")
  • 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)


> Ballot Initiatives: Finally, all eyes are on the November 5 Florida ballot for obvious reasons and Yes on 3 (Amendment 3) is polling in the mid-60s.  The industry could see further catalysts in North Dakota's Measure 5 and South Dakota's Initiated Measure 29 for adult-use, and Nebraska's Initiative 438 medical legalization. Sadly, South Dakota's Initiated Measure 29 is polling poorly, and the initiative related to the expansion of Arkansas's medical program was already struck down by the AR Supreme Court and the votes will not be counted.

Marijuana Moment will be doing a fantastic job of keep track of all of these and more on November 5th.


cannabis advisory agency

To have a conversation about cannabis in your state or any other jurisdiction, call Jamie at 302-750-9678 or schedule a conversation


The cannabis space will be more daunting than ever in 2025.


And the stakes are now so much higher as industry mechanics develop in two dozen state-based markets. Cannabis isn't remotely recession-proof and the 10-year (to never) wait for federal legalization has completely turned off institutional and retail investors. Regulatory reform is a bad bet, the East Coast has quickly become cannabis country and even calculated growth requires outsized CAPEX.


Rescheduling cannabis from S1 to S3 seemed effectively a done deal though the mic drop catalyst that the publicly traded company stocks desperately need will come in 2025 instead of being part of any October surprise. 


Consequently, 280E relief is now a 2025 event and the IRS has come right out and said that MSOs taking the refunds ahead of time is uncool. The American Institute of CPAs has queried the Department of the Treasury and the Internal Revenue Service for guidance in advance of the impending transition.


Institutional capital and pubco uplisting is still beyond the horizon though some pensions and other allocators are looking to move money toward cannabis. While state-based banking reform has gained momentum, SAFER isn't happening and the CSRA and intoxicating hemp will occupy any lame duck congress cannabis discussion. Even some of the stronger holdout operators are starting to fold in the trickiest markets like California, Oregon, Oklahoma, New Mexico, Michigan and Massachusetts.


As financing remains scarce, the pinch is felt industry wide with smaller single-state operators and cultivators nearly everywhere taking the biggest hit. Capital is far too constrained to sustain the measures of price compression and normalization being experienced across the heavily and even not so heavily taxed mature markets. Operators trying to stand up licenses in NY, NJ, CT, MD and DE are starved for the necessary resources.


Call or text Jamie at 302-750-9678 today to discuss your current place in the cannabis industry and plans for the uncertainty and undeniable growth that lies ahead.



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