How to Get In the Legal Cannabis Industry Without Being a Supplemental Applicant 

The supplemental individual prequalification application for a medical cannabis facility license consists of 8 disclosures, including:

  • 1 year of financial information,
  • 3 years of tax compliance,
  • criminal history,
  • 7 years of litigation history, and more.

The supplemental individual prequalification for an adult-use/recreational marijuana business has fewer requirements such as disclosure of 12 months of tax compliance, criminal history, 5 years of civil litigation history and so on.

However, those who wish to apply for an adult-use Class B or C Grower, Processor, Provisioning Center or Secure Transporter license must first hold a medical marijuana facilities license.

After your application disclosures and supporting materials are submitted, you are then required to complete a fingerprint request. This process is part of a much more comprehensive background check. If you are not prepared to commit to the intense review of the step 1 prequalification application, there are other ways you may still be a part of the marijuana industry. 

Money Lender

Each license type is required to demonstrate an amount of capital to verify the business is able to operate and maintain the proposed facility. Capitalization requirements range from $150,000 – $500,000 per license depending upon license type, and must be at least 25% liquid assets. If you wish to be involved in the industry as an investor, you could do so as a money lender.

As a money lender, you would be required to execute a lending agreement with the applicant entity to define the terms of your loan. Additionally, you would have to disclosure your name, social security number, date of birth, address, contact information and the nature of any interest you may have in the proposed facility. Proof of funds or evidence of the value must also be shown.

READ  Requirements for Licensed Cannabis Businesses on Selling Marijuana Vape Pens

While this can be a successful investment, you will likely have little control, if any, in the proposed marijuana business.

Business Owner with Less than 10% Interest 

If you own less than 10% of the applicant entity and do not have any managerial control, you are not required to complete a supplemental individual application. However, you will be identified on the entity’s prequalification application.

For such purposes, managerial control refers to the ability to create and enforce policy. You will be required to provide your social security number, address, spouse’s name, and spouse’s social security number for the applicant entity prequalification application.

The Marijuana Regulatory Agency (MRA) will review the applicant entity’s structure and membership roles. It is extremely important to accurately disclose your title and responsibilities in the entity. If it appears you may have managerial control, the MRA may have follow-up questions or request additional documentation.


If you wish to be an employee of a licensed marijuana facility and do not hold more than 10% interest or have managerial control, you are not considered a supplemental applicant. Your employer is required to complete a background check confirming your criminal history.

READ  The Most Recent Update on the SAFE Banking Act

To be an employee of a licensed marijuana facility, you may not have been charged with or convicted of a felony in the last 10 years. Those with a felony in the last 10 years may still be considered for employment, but are subject to MRA approval.

Consulting with a Cannabis Attorney

It’s vital to have an experienced cannabis attorney assist you with the application process. Doing this will ensure that you are starting on the right foot in this exciting yet complex industry.

Kali Rose (14 Posts)

Kali is one of Cannabis Legal Group’s Paralegals. She began legal career at the Law Offices of Barton Morris and Cannabis Legal Group in 2017 as an Administrative Assistant. In July 2018, she was promoted to Paralegal at Cannabis Legal Group. She earned an Associate of Applied Science from Terra State Community College in Fremont, OH and holds background in communications and marketing. Kali is responsible for client relations, managing attorney calendars, and works to ensure research and document support are carried out effectively and efficiently for our cannabis clients.

Share this Article