 I'll get started then. My name is James Pepper. I'm the chair of the Vermont Cannabis Control Board. Today is April 4th, 2022. And I call this meeting to order. So today, before we get started, I just wanted to address some of the common questions and issues that we've been receiving from applicants. First, an update on pre-qualification. Just remind folks that this is a voluntary process. It's voluntary. We, it's not a requirement for licensure. We created this process because we determined that there are benefits both for the applicants and for the board. With respect to applicants, first and foremost, if you have a criminal history record, you might not be able to qualify for a license. This is an odd sort of industry. If you're growing tomatoes, no one cares whether you've had a prior conviction for money laundering, for instance. However, if you're growing cannabis, a conviction for money laundering might mean that you can't have a license. The pre-qualification process is designed so that the board can tell you whether you have something going on in your past, whether that's a criminal conviction or a civil or an administrative adjudication, it would disqualify us from granting you a license. And we want you to know that before you make any sort of capital investments in lights or an HVAC system, or you enter into a long-term lease agreement. So that's a benefit for you if you have something going on in your past that might disqualify you. The second benefit for applicants, we've heard from banks, we've heard from insurance companies, we've heard from towns, we've heard from other Vermont agencies that they don't want to waste their time talking to a prospective business owner that might not ultimately qualify for a license. And so a number of those institutions are requiring that an applicant have something from the board, a letter, something that shows them that you are able to participate. So that being said, if you're a person who doesn't have any criminal convictions, if you don't have any civil or administrative adjudications that might be problematic, if you know this is true of all of your business partners as well, or anyone that has a financial stake in your business, if you have a bank account, if you have insurance, if your town has already given you a green light, you probably don't need to seek pre-qualification. And just to be clear, there are benefits to the board as well. We are getting an early picture of the market, which we're using to help inform our decision-making, making sure that there aren't any obvious bottlenecks in the supply chain. But I can tell you there's no financial benefit to the board about pre-qualification. I think anyone who's been watching our work or our testimony in the legislature should know that the fees that we're charging are not sufficient to cover our operating expenses. Essentially, we recommend it to the legislature that they subsidize the cost of fees in order to keep them low so that people have the ability to participate and use a portion of the excise tax to support our functions. So just to sum up, pre-qualification is voluntary and everyone should decide for themselves whether it makes sense for them. A quick update on the numbers. We've received 565 pre-qualification applications. This is in all areas of the supply chain. We've had the vast majority of cultivator pre-qualifications have been for tier one, although we do have pre-qualification applications at all tiers of cultivation. We've had 84 pre-qualification applications for retail establishments. We've had 85 for manufacturing, 25 for wholesalers, eight for testing labs. And we've had nine for integrated. Obviously, there's some confusion in the industry about who qualifies. Those are only available for the existing medical dispensaries. So we'll be in touch with the people that try to pre-qualify for the integrated specifically. I think our plan is to post all those numbers that metadata about pre-qualification so that the entire industry can kind of see how this market is shaping up. And we are gonna be issuing pre-qualification approvals today. We're just gonna start slowly, but fully intend to speed up. Now that we have some procedures in place and infrastructure in place, including our kind of conflict of interest policy, which we'll be reviewing later today, our BRAC background check procedures, our online payment portal. And someday soon, hopefully we can hire some staff, some licensing staff. But an update on our first licensing window opening, we've had 10 applications that have been fully submitted. The board has not reviewed these for completeness, but they've at least satisfied all the kind of mandatory fields and have been fully submitted. We've had over a hundred more that are in various stages of completeness in the kind of draft form. So that's a good early sign for the market. With respect to fingerprinting, just an update on fingerprints. In order to comply with the FinCEN guidance and our statute, the cannabis board is required to obtain a 50 state fingerprint supported background check from the FBI for all cannabis applicants, all principals of these businesses and all employees. And we are required to disqualify people with certain types of criminal convictions. The board applied to the FBI for the authorization to receive these records on April 27th, 2021. So almost the year ago. And we haven't heard anything from the FBI despite repeated attempts for information. We've had a recent, one of our recent inquiries indicates that the FBI intends to deny our authorization because our statutory definitions of applicant and principal and employee are not specific enough for them to feel comfortable releasing these records to us. We've been in touch with some other states that have legal cannabis markets and this exact issue is coming up across the country, including in more recently adopted legal states and some of the more mature legal markets. The themes that we've been hearing as we talked to other regulators is that engaging with the FBI and modifying statutory definitions has not been successful. Modeling these statutes, these statutory definitions on states that have FBI authorization is also not been successful. That the FBI might be reconsidering some of its prior authorizations to more mature legal states and that the FBI is backlogged for several weeks and months. So even if we were to get a statutory fix, it's unlikely that this issue will be resolved by May 1st when we have to start issuing licenses. So we've been working on contingency planning around this. The current plan is that we are not gonna require fingerprint supported background checks for your operating license. During the application process, we were gonna ask you to share with the board all the places that you have lived or conducted business for the past seven years. And then the board is contracting with a third party vendor to conduct background checks in those states. This process is not ideal. It will involve an additional cost to the licensee. And we will kind of reach out to you when the time is right about how to get that background check conducted. We'll also just keep all of our application materials and all of our guidance up to date on this issue. With respect to payments, we do have the ability to collect fees for pre-qualification online. And we will also have the ability to collect fees for operating licenses online by May 1st. You do not need to submit payment until you're prompted by the board to submit payment. See to sale tracking. We've been getting a few inquiries about inventory tracking. So inventory tracking is a very important part of the industry, not just because it's required by our laws. It's also important to prevent the federal government for prioritizing Vermont for enforcement. And it also helps prevent product that's grown out of state from flooding into our markets to the detriment of our in-state cultivators. See to sale tracking is also an incredible source of frustration and cost to every kind of licensee. And to regulators. We do not wanna force the system onto this industry that's expensive, that takes a lot of time and resources to understand and to comply with, only to have us change it down the road. So we have been and we are continuing to evaluate all of the options, both in the short-term and the long-term for see to sale tracking. We're not ready to announce anything more specific at this time, but we will have inventory tracking as part of our regulatory structure as soon as we start issuing licenses. With respect to social equity, we've been getting quite a few calls about people wondering why they don't qualify for a fee waiver. I just wanna say that the legislature gave us pretty strict parameters on who qualifies for a fee waiver. It's in section 11 of Act 62. The cannabis board shall propose a plan for reducing or eliminating licensing fees for individuals from communities that have historically been disproportionately impacted by cannabis prohibition or from individuals who are directly and personally impacted by cannabis prohibition. The second prong is pretty straightforward. The board decided that if you or a family member has been incarcerated for a cannabis-related offense that you've been personally or directly impacted by cannabis prohibition and you qualify for a fee waiver or fee reduction. The first prong was a little bit harder to define. How do you draw lines around which communities have been historically disproportionately impacted by cannabis prohibition and which have not? Other states that have done this have looked at historic records from law enforcement agencies around drug arrests and looked for either zip codes or policing districts that show trends in over-enforcement for drug offenses. These systems are subject to gamesmanship. It's been playing out around the country. A neighborhood that maybe was over-policed 30 years ago has now been gentrified and no one currently living there has actually been disproportionately impacted by those drug arrests. You see companies that are buying or leasing commercial space in these neighborhoods in order to qualify and yet they have no disproportionate impact from they've not been harmed by cannabis prohibition. More fundamentally, we tried this approach in our social equity subcommittee. We looked at data from policing in this state. It was either non-existent or it created these disproportionate impact areas that included large swaths of the state. It looked like everyone in, for instance, Chittenden County or Bennington County was gonna qualify as a social equity applicant whereas no one from SAX or Washington County. And that kind of arbitrary line drawing doesn't really jive with the idea that we're looking for people that have been disproportionately impacted by cannabis prohibition. We also looked at economic opportunity zones which was tied to a federal program that created tax incentives for certain parts of the state. We ran into the similar problem of arbitrary line drawing. Everyone, for instance, south of Main Street and Barry was in an opportunity zone but no one north of Main Street is. How is that helpful in us trying to define communities that have been historically disproportionately impacted by cannabis prohibition? So we did what we felt was justifiable. We said, you're a social equity applicant if you're a black American or a Latino American or you can demonstrate that you're from a community that's been disproportionately impacted. There are a large number of reports nationally and in Vermont that demonstrate the disproportionate impact of the war on drugs on black and Latino Americans in traffic stops, in arrests, in charging and in sentencing. So this isn't to say that there aren't similar impacts on other demographic communities. We know there are many people in this state and nationally that are discriminated against because of the color of their skin, because of their ancestry, because of their sexual or gender identity, because of their socioeconomic status and any other reason. If you feel like you're from a community, however you want to define that, that historically has been disproportionately impacted by cannabis prohibition and you're not black, you're not Hispanic, you've never been incarcerated for a cannabis related offense, you can still make your case to the board. Let us know and we'll evaluate that case individually. And if you're frustrated by the social equity program or the decisions the board made or if you have comments or concerns, I would encourage you first to go back and watch our subcommittee meetings and our board meetings around this decision. And then two, reach out to me directly. My email address is james.pepper at vermont.gov. Our staff did not have any input on this decision and they really don't have the time to kind of explain the process that the board went through. One last piece on social equity. We are pausing our social equity networking events for the short term while we kind of turn our attention to licensing. And if anyone has any just general questions, a lot of our guidance is available on our website at ccb.vermont.gov slash creep qualify. If you're not seeing things there, you can always email the board. It's ccb.info at vermont.gov. We do have a phone as well for trying to kind of diligently get back to people as quickly as we can. The phone number is 802-828-1010 and it's option zero for the adult use program. All right, other than that, we just need to approve the minutes from March 28th. Is there a motion? To move. Seconded. All in favor? Aye. All right, so first on the agenda is we need to formally adopt rules three and four. We've done this for one and two. So same process for three and four. They've been through Elkar and now we just need to formally adopt them. Yeah, that's right. Not much more to say than that. Elkar approved them on Thursday. We just got the formal letters of approval this morning. The only edit that came during the Elkar process was that the term fine in rule four is now going to be called an administrative penalty in order to make our rules as confusing as they could be. I'm just kidding. It does make it a little less clear. We'll have administrative penalty to find them and rule them of course. And our many guidance documents will be clear about what administrative penalty means. But that was just to bring the rules in line with standard legal usage in Vermont regarding what we call non-criminal monetary penalty. But that's it. Everything else exactly the same, not even any other technical edits really to rules three and four is very much what it was when it was sent to Elkar. It's ready for your vote to adopt. Thanks for your hard work. There are motion to adopt rules three and four. I'll motion to adopt rules three and four. Can we do it together? I can. Can we do it in one fell swoop, David? Yes, you can do both at once. Yeah. All in favor? Aye. All right. So next we're going to move towards approving some of our pre-qualification applications. Before we do that, we spent some time last week in the week prior developing a conflict of interest policy that the board's going to follow. And I'd like to go ahead and just maybe walk through some of the finer points on that policy. Sure. So I'm going to try to put up a PowerPoint here and I'm just going to run through the statute that really drives the board's requirements on this front and explain how the statute sort of translates into how this will be used. So we'll do a little bit of a policy in process. Should be, I don't know, five, six minutes here at the most. So the statute that really governs board conflict of interest is 7VSA 843D, which is in the chapter 31 of Title VII, which lays out the board's existence and duties and all of that. Some parts of state government aren't driven by conflict of interest stuff that's driven by policy. The governor's ethics guidance or document is it drives other parts of state government. But in this case, the board really has a statute that's going to be controlling a lot of the key issues. So I'm going to read through sections one, three and four of this and then we're going to return to section two. One, three and four are really just prohibitions and things that the board members simply can't do. No board member shall during his or her term or terms on the board being officer of or director of, organizer of, employee of, consultant to or attorney for any person subject to regulation by the board. Rule three, no board member shall during his or her term or terms on the board solicit, engage in negotiations for or otherwise discuss future employment or a future business relationship of any kind with any person subject to supervision or regulation by the board. And section four, no board member may appear before the board or any other state agency on behalf of a person subject to supervision or regulation by the board for a period of one year following his or her last day as a member of the cannabis control board. So that's all pretty straightforward. Just doubt, shout nots, can't do it. If you were to do it, it'd be in violation of the law. We're turning now to section two. Well, pull that out and tease it apart a little bit. It's as in a lot of statutory language it isn't the most straightforward but I'll read through it and then we're going to pull it apart and show how it is translated into the policy the board will follow. No board member shall participate in creating or applying any law, rule or policy or in making any other determination if the board member individually or as a fiduciary or the board member's spouse, parent or child wherever residing or any other member if the board member's family residing in his or her household has an economic interest in the matter before the board or has any more than a de minimis interest that could be substantially affected by the proceeding. So I'm sure everybody understood that perfectly reading through it, but just in case we did break it down a little bit. So it'll be a little more usable when board members are trying to determine if they do have a conflict. So if we look at that first sentence there this basically sets up the provision saying no board member shall participate in creating or applying any law, rule or policy or in making any other determination if they need a set of criteria and that set of criteria is a conflict of interest and there's a constant conflict of interest. So in the sort of beginning of our little policy it just says no board member shall participate in creating or applying any law, rule or policy or in making any other determination if the board member has a conflict of interest. Okay, great. So what is a conflict of interest? Well, the rest of the very long sentence here lays that out, but let's go through it. Actually the last piece of it that lays out what the interests are. So it's saying that there's a conflict of interest where if you're in a certain group of people and we're going to return to the certain group of people in a moment, but if you're within a certain group of people that has an economic interest in the matter before the board or has any more than a de minimis interest that could be substantially affected by the proceeding there will be a conflict of interest if you're one of the following people. If the board member individually is fiduciary the board member's spouse, board member's parent, board member's child or any other member of the board member's family residing in his or her household. And so when you pull it apart like that I think it's a little bit easier to use and I see there's an error here that should be A, B, C, D, E but we'll pick that. And that's basically the policy you can see how it's really taken directly from statute and this is I should say it is in addition to 843, D, 1, 3, and 4 which are just the prohibitions on board behavior but this is the one where board members are gonna have to take a look at the application applicants, the individuals and entities to determine if they fit into one of, if they are one of these individuals and if they are is there an economic interest or is there any more than a de minimis interest that could be substantially affected by the proceeding? And then de minimis is defined in many, many ways depending on the context and place just doing a little research on this. It's certainly not defined in this statute it's rarely defined other than by the specific context in which it's being used. So as a guidance but not as a definitive definition well the board can be guided by this knowing that there will be other things that will have to be discussed if there is any issue but a de minimis interest could include but it's not limited to an interest that is no greater than that of other persons generally affected by the outcome of matter or an interest that has such negligible financial impact as a negligible financial impact such that it could not reasonably be seen as influential in a person's decision making. So that's the sort of policy and then just briefly on the process it's really pretty simple. When determining whether they might have a conflict of interest in the context of licensure decisions board members will review names of persons and or entities having control of proposed cannabis establishments principles and financiers without knowledge of their associated applications. In other words board members are gonna take a look at lists of people who have applied or lists of entities that have applied to make sure that that list does not contain somebody who's within that group of people that could create a conflict. They're not gonna look at the associated applications and they do that in order to just keep focused on the individuals. And then obviously if there is a conflict of interest they'll accuse themselves and then in determining whether to grant licenses board members will generally review anonymized applications and that's both to ensure trust in the conflict of interest process that applications will be anonymous. Obviously if there has been a conflict determined the board member will be recused but just to add an extra layer. There might be some cases where a name itself like the name of entity itself could provide an issue with respect to a potential rule violation like a misleading representation or something of that nature. So in a circumstance like that it may be impossible to do a fully anonymized review but short of that hopefully we won't see too many of those. This will be reviewed anonymously and I should say applications will be reviewed anonymously and that's it. Can I ask a question? So this is about really about approving applications and that specific group of people but then we also talk about not answering direct questions for potential licensees and I know that you talk about this almost the beginning of every public meeting but can you talk about the reason for that just so that there's no confusion that we're not changing anything. This is additional but we're still not able to answer those types of questions. That's exactly right. There's really a few reasons why you can't answer those types of questions but I mean the main thing is that when you're answering questions and a sort of question answer session you really don't have all the information that you're gonna have when a license application comes in. I know that folks answering and asking the questions are not trying to hide anything and trying to tell you the full story but it's just the nature of how that happens. A license application gather a lot more information than just a question answer session. So what you're doing in attempting to answer a question like that or give some sort of potential signal about what might happen is you're sort of giving an assurance to somebody about how their application process might go without any ability to make a promise on that basis. And so people could change their behavior or make an assumption about how something's gonna happen or even make an investment on the basis of something like that when in fact that may turn out to be wrong in the full light of complete license application. And then you as a board member have put yourself in a position of having made an indication about how this is gonna go when it comes before the board which is not something you can be bound by because it isn't in the normal process and you've potentially harmed an applicant by doing that and you put yourself in a it may or may not be a technical conflict of interest in the way the statute defines it but you certainly put yourself in an ethical brazen where you're saying, hey, we think this is okay. And then you have to turn around and reverse yourself in a formal meeting later which is not a good place to be in and it could give an applicant some sort of a cause of action against you at least to not end up sort of like going to court sense but certainly like challenging how the board process had happened and potentially the administrative law judge. So for all those reasons that's why you shouldn't be answering questions and I know the pepper gives those caveats probably very similar to what I just said at the beginning of those meetings and it's similar to the conflict of interest issue not exactly what you'd like to say. Okay, thank you. Any other questions for David? Thank you, David. No problem. That was great, thank you. I would just say also though that we all also assign the governor's ethics pledge when we're creating our rules we're all operating under that ethics pledge we continue to operate under it but I think it's pretty clear that the three of us don't have and will not have a financial stake in the way that we drafted the rules when we're moving to a new phase where we're actually issuing licenses I thought it was important for us to have this clear with respect to the people that are gonna be receiving these licenses. Oh, that's a good point and you certainly are still bound by the governor's ethics pledge for anything any question that isn't answered by your statute specifically. Great, all right. So I think now we can move on to actually reviewing the or approving some of the qualification applications. Yep. So I do have a document for us to go through with the pre-qualification application review submissions that we're gonna look at today but first I thought this is our first time doing this review and I thought I would go through a little explanation of what was reviewed and what the staff recommendation is based on. So because the pre-qualification inquiry is limited in scope because if it is what it is it's not a license to operate. This is going to be a much simpler process than the review process would be for the full license application. So the reviewers for pre-qualification applications are checking for four things. Completeness of the application, the sufficiency of each requirement within the application whether the criminal history record reveals any presumptively disqualifying offenses and then a confirmation that the business is not the business applicant isn't in violation of the one license rule. This is our first batch today that will inherently not be true today. So for completeness of application just a reminder of what that means for the pre-qualification application is the pretty limited list. We are looking for the business name and the point of contact with the board. The names of all the principles and controllers and any relevant documents that demonstrate any control relationships. Also federal tax IDs and social security numbers for that list of folks. Documentation that the applicant is an entity that's registered to do business in Vermont. The applicant's full legal name, any aliases, their address, their date of births. A copy of their driver's license or other government issued ID. And a fingerprint supported identity history record from the FBI that's required through our guidance that's the criminal history record check. And then the narratives that they are subject to provide which include the description of any criminal action against the applicant or any principal or controller of the business. Description of any civil action then the proceeding 10 years for the same group of people. Description of any administrative action that's been commenced against that same group of people. And a description of any disciplinary action against a license registration or certification that's been held in any jurisdiction by that same group of people. So that as long as all of those criteria are met then the application can be considered complete with respect to that portion of the review. And then the sufficiency of each requirement is reviewed. So all information conveyed has to meet the criteria that's set out in the rule. Whether the entity is registered to do business in Vermont they have to submit some documentation that supports that for example, articles of organization or a business registration certificate that's been filed with the Secretary of State's office. Is the identification provided sufficient? Is it issued by the government? If it has a photograph. And then is the criminal history record conveyed in the appropriate format? Is it given to us the way our guidance requires it to be given to us and a sealed envelope from the FBI or electronic copy? And then does the narrative provided regarding the criminal history record match with the actual record check from the FBI? Assuming that all of those are sufficient then we move on to the next two inquiries. The first is whether the criminal history record reveals any presumptively disqualifying the census. And lastly a confirmation that the business is not in violation of the one license rule which will be a more complex inquiry as we move on and people are issued pre-qualifications or licenses. So applicants that are pre-qualified will be provided a letter certifying that they have been pre-qualified by the board and they will also be notified of their submission number so they can watch the board meeting at which their application was reviewed. So today we have four pre-qualification applicants up for review and as the chair mentioned that the outset our staff really have been focused on setting up like the internal framework for receiving and organizing and storing applications. Now that that process has been established we anticipate having a greater number of patients to review each week. So here's our list of four submissions that are up for review this week. And as we just went through the individuals involved in the business are going to remain anonymous. So for submission number 12, that's how we are anonymizing these and assigning them a submission number and leaving out the individuals in the business name. So for submission number 12, they are seeking an outdoor tier one cultivation license. They are not an applicant or a licensee for any other license type and they have met the criteria for sufficiency, their application was complete, their criminal history record demonstrated no presumptively disqualifying criminal offenses. So therefore the staff has determined that they are suitable for pre-qualification and recommend our qualification. Submission number 36 is seeking an indoor tier one cultivation license. The submission also did not, the applicant isn't an applicant or a licensee for any other license type. And again, they demonstrated sufficiency of all of the requirements and their criminal history record revealed no presumptively disqualifying offenses. And so board staff finds them suitable and recommend the submission also for pre-qualification. Submission number 60 is seeking an indoor tier one cultivation license. Again, they are not an applicant or a licensee for any other license type. They have met the sufficiency requirements, their criminal history record revealed no presumptively disqualifying offenses. So board staff found this application suitable and recommends them for pre-qualification. And lastly, submission number 140, seeking an indoor tier one cultivation license. This applicant is also not an applicant or a licensee for any other license type and their application was also sufficient, complete and their criminal history record revealed no presumptively disqualifying offenses. So the board finds their application suitable and recommends mission 140 for pre-qualification also. And the rest of this document, I think you've reviewed already which is the submission summary. Not first, so I won't go through that. All right, any discussion about either the process or any questions about these four applications? Nope. Okay, and we've all reviewed, we don't, it's anonymized, but we've reviewed the principles of each to ensure that none of us have any sort of conflict of any, we don't implicate the conflict of any policy. Yes. Okay, then why don't we vote to, is there a motion to approve these in two weeks? Can we do it all at once? I'm sure we have some more. Oh, excellent. I'm prepared. All right. Move that the board accept each of the recommendations for pre-qualification approval as presented to us by staff in this meeting. Wait, is there a second? Second. Any discussion at all? All right, all in favor? Aye. Aye. So Brandon, now you're gonna notify these 12, or these four applicants. Yep, each of these applicants will be notified given their submission number and only to the meeting and also they will be presented with a letter. Sorry to find them as pre-qualified. Okay. All right, anything more for pre-qualification then? Not today. Okay, and our plan is to do more on next Monday. And really, I think, start with the small cultivators. Really trying to get them done with all the people that kind of have their application window open on April 1st. I think it's smart to start there to get them qualified and then kind of move through the rest of the applicants based upon that kind of statutory timeline. All right, well, then why don't we move to public comment? We'll handle it the kind of same way we always do. If you have public comment, please raise your virtual hand. Then we'll move to folks that have joined by the phone just to reiterate that the board really cannot answer questions during public comment sessions. They're designed for the public to provide feedback and participate in the decision-making process of the board. We really can't be in the position of answering people's direct questions. And we do have an email address that people can submit their questions to. Do try and keep our frequently asked questions up to date. And we use your questions to help inform those. But why don't we open it up to public comment and maybe Nellie could help us with the order. That's the plan. Dave is up first. Hey all, good morning. I hope that the pace will pick up as 565 prequels at four a week will take a few years. Regarding background checks, I guess my thought here is my clients, the applicants will go through whatever process you guys put out there of course. But we have found that the prequel background check process was workable of getting your own FBI background check results and submitting those to the board. And it just when you mentioned earlier the idea of having a vendor go state by state to each state where you've lived in the last seven years, it just sort of seems like that's a cumbersome process when we do have a way to get you the 50 state fingerprint based background check results. So just thought I would put that out there. Thank you very much. Thanks, Dave. Next is Jesse. Oh, with OGO? I could just one other people have their hand up for me. Hi, little taking them back. I just had a quick question for you guys. No, I'm kidding. I'm kidding, I don't have a question. I was just gonna say pretty much the same thing as the last person did. And also just suggested maybe, I don't know if you guys you probably have thought about it, but people that did the prequel and already did the background check and sent like a sealed envelope. If maybe that would suffice for full licensing instead of the state-to-states because I have a couple traveling hippies in my gang and oh my gosh, you guys do not wanna see the states they've lived in the past seven years. So that's all I have. Thank you guys for your hard work. Ian, I will see you next week. Thanks, Jesse. I don't see anyone else with a hand up close. Jason, Jason Corsano. Yep, you can hear him on now. Thanks, I appreciate it. I actually have a question, maybe a concern and then maybe a recommendation. So I'll start with the question. I didn't necessarily hear for the pre-qualification. Does the fee have to be paid 500 in order for us to get pre-qualified? I didn't hear it that clearly. And then as far as the network that we're working on, collecting all individual data from bank account to everything, I do have some concerns with just the security of the network. And I just thought that maybe I'd bring that up and maybe you can build some confidence by addressing what you have done and maybe some simple things with a basic text or email code verification simply like every other platform that has secure information. And then as far as maybe a recommendation for next year concerning the budget for the CCB because that's really what dictates the flow of things over the years, the growth, the success of this whole program. So if your budget doesn't work then the program is not gonna work. So with concerns with that, I guess one solution in my mind would be for the integrated licenses that are going to be issued and in the future most likely no more of them possibly. It just would behoove the CCB to maximize that fee to the minimum of if an Apple can applies for all the tiers that an integrated license can apply for and have unlimited, I believe, canopy. It would make sense to go to $149,000 versus a hundred because that would be each individual license at its maximum and that would just be a little bit more, make more sense, it'd be more fair even though the start of it doesn't seem that it started that way. But I think that would bulk up another $50,000 for each one of those licenses and that might be a quick solution. Thanks a lot for listening. I appreciate all the work you guys are doing. Thanks, Jason. All right, we have THC analytics. Yeah, just a quick one and this is more of a concern than anything. We pre-applied for the pre-qualification and we never received any follow-up emails. That was it. Thank you, appreciate it. Thank you. So I don't see any other hands. If there's anyone that joined via the phone, you can unmute yourself by hitting star six. All right, we'll close the public comment window. Just with respect to the pre-qualification, yeah, the fee is a prerequisite of being pre-qualified. We didn't have the ability to collect that online. We didn't have the authority, I should say, to collect it when we open our pre-qualification window. But if you sought pre-qualification, you will be notified by the board about paying the fee and THC analytics. I'm sure someone will follow up with you after the meeting to make sure that your application was submitted properly. Anything else, anyone? Did you want to reiterate why we can't use the information that's already been submitted for the background check? I think you sort of touched on it in the beginning, but. Right, the 50-state support fingerprint supported background check is set up by statute. The process is set up by statute that we have to work through the BCIC, the Center for Crime Information Center to request the information from the FBI. It's a very specific process that's laid out. And so we've evaluated whether or not the kind of process that we use for pre-qualification could satisfy what we need to do. We're not sure that it actually meets the kind of specific statutory language. So we've created an alternative system. We've evaluated this proposal, though. And so I would just say we're going to keep our guidance on this up-to-date and our application materials will reflect what we need. So I would just say that we have a backup plan if the FBI doesn't give us this authorization by May 1st. And we'll just make sure that anyone is seeking the licenses aware of what's required. Thank you. Yeah, thank you. I would just reiterate, because I know we at least heard from one commenter there was only four today. But I want to applaud our staff for even getting us four. There's a lot of processes that we need to set up. Part of that is also making sure folks are giving us all the information that we need, and that we're not constantly hunting down that information to pre-qualify somebody. So that's a two-way street, and I would expect there to be those to climb it. These, hopefully, an exponential rate, but at least a linear rate over the next couple of weeks. So have no fear. Great. Well, it's the end of our agenda. So I will adjourn the meeting, and we'll be back next Monday. Thanks, everyone.