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extracted/summaries/house-oversight-nov/24/house-oversight-024663.txt

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+ACKRELL
+CAPITAL
+CHAPTER II Cannabis Science 101
+THC and CBD Formulation Spectrum
+Balanced
+THC Dominant
+THC:CBD
+10:1 to 25:1
+THC:CBD
+25:1 to 100:1
+THC Level
+THC:CBD
+5:1 to 10:1
+THC:CBD
+4:1
+THC:CBD
+1:4
+THC:CBD
+1:5 to 1:10
+CBD Dominant
+THC:CBD
+1:10 to 1:25
+THC:CBD
+1:25 to 1:100
+CBD Level
+• Alzheimer's disease
+• Anorexia
+• Appetite stimulant
+• Chronic pain
+• Amyotrophic lateral
+sclerosis (ALS)
+• Cachexia
+• Cancer
+• Glaucoma
+• Hepatitis C
+• HIVIAIDS
+• Migraine
+• Multiple sclerosis
+• Nausea
+•...

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+ACKRELL
+CAPITAL
+CHAPTER II Cannabis Science 101
+Cannabis Plant Tissue Cultures
+Synthetic cannabinoids and terpenes can be manufactured by modifying plant-based compounds
+or through tools of synthetic biology and biocatalysis. For example, a synthetic version of THC
+known as dronabinol is the active compound in the pharmaceutical product Marinol, which was
+approved by the FDA in 1985 for use in treatment of nausea and vomiting associated with cancer
+chemotherapy. Methods for biosynthetic...

extracted/summaries/house-oversight-nov/24/house-oversight-024666.txt

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+ACKRELL
+CAPITAL
+Cannabis Investment Report | December 2017
+Representative Dosage Amounts
+Desired Effect or Ailment
+"High"
+Anxiety, depression, spasms
+Cancer
+Chronic pain
+Epileptic seizures
+Glaucoma
+Increased appetite
+Multiple sclerosis
+Schizophrenia
+Sleep disorders
+Dosage
+10 mg THC
+25 mg CBD
+25 mg CBD
+2.5-20 mg THC
+200 - 300 mg CBD
+20-40 mg CBD
+2.5 mg THC
+2.5-120 mg THC
+40-1,280 mg CBD
+40-160 mg CBD
+Dosage Ratio
+(THC: CBD)
+10:1 to 100:1
+1:10
+1:1
+10:1
+1:5
+1:2 to 1:4
+5:1
+1:1
+1:4 to 1:128
+1:4 to...

extracted/summaries/house-oversight-nov/24/house-oversight-024667.txt

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+ACKRELI
+CHAPTER III
+Cannabis Industry Segmentation
+The nascent cannabis industry is often viewed by investors and others as a single, homogeneous indus-
+try, in much the same way the "technology" industry was viewed in the early 1990s. As the technology
+industry became more important to the global economy and was better understood by the investment
+community, however, investment banks and other industry analysts tracked an increasing number of
+discrete yet related industry segments. In the...

extracted/summaries/house-oversight-nov/24/house-oversight-024669.txt

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+ACKRELL
+CAPITAL
+CHAPTER III Cannabis Industry Segmentation
+Time
+Start
+Cultivation Process Overview: Seed to Bud
+Seed Selection
+Selecting a seed is the first step of the cultivation process. A cultivator can
+choose from more than 1,500 unique seed varieties, each of which has the
+capacity to produce a cannabis strain with a particular cannabinoid anc
+terpene profile and other unique characteristics
+1-4
+Weeks
+Seedling
+The seedling stage is the period during which the seed sprouts and the
+plant...

extracted/summaries/house-oversight-nov/24/house-oversight-024670.txt

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+ACKRELL
+CAPITAL
+Cannabis Investment Report | December 2017
+Cultivation Facilities
+There are three general types of cannabis cultivation facilities: outdoor facilities, where cannabis is
+grown under natural sunlight and widely exposed to the elements; greenhouse facilities, where canna-
+bis is grown under filtered sunlight and environmental conditions are partially controlled; and indoor
+facilities, where cannabis is grown under electrical lighting and environmental conditions are...

extracted/summaries/house-oversight-nov/24/house-oversight-024671.txt

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+ACKRELL
+CAPITAL
+CHAPTER III Cannabis Industry Segmentation
+Compared to indoor cultivation facilities that use electrical lighting, greenhouse and outdoor facili-
+ties are generally less expensive to operate and more appropriate for large-scale projects, but provide less
+control over growing conditions. Outdoor and greenhouse cultivation facilities are prevalent in
+Oregon, California and certain Latin American countries, which have climates conducive to outdoor
+growing. Outdoor Greenhouses
+The...

extracted/summaries/house-oversight-nov/24/house-oversight-024672.txt

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+ACKRELL
+CAPITAL
+Cannabis Investment Report | December 2017
+Production Equipment and Supplies
+Production equipment and supplies include the physical components used in cannabis production. Some components of cannabis production are similar or identical to components used in other
+agricultural industries (such as irrigation systems), and some are specialized for application to the
+cannabis industry (such as extraction machines). Specialty cannabis equipment companies now provide
+"all-in-one"...

extracted/summaries/house-oversight-nov/24/house-oversight-024673.txt

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+ACKRELL
+CAPITAL
+CHAPTER III Cannabis Industry Segmentation
+potency, moisture content and the presence of contaminants, such as residual solvents, heavy met-
+als, mycotoxins, microorganisms and pesticides. Uniform standards for testing and reporting are expected to
+emerge as scientific understanding of cannabis increases and as industry consensus about cannabis-
+related health and safety concerns develops. Composition and Potency
+Laboratories ordinarily test cannabis for the specific amounts of...

extracted/summaries/house-oversight-nov/24/house-oversight-024674.txt

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+ACKRELL
+CAPITAL
+Cannabis Investment Report | December 2017
+sclabs
+Sample Name:
+Tested for:
+Sample ID:
+Date Tested:
+Potency Test Results
+erformance Liquid Chromatography (HPLC/JV
+Cannabinoid Summary
+Total THC
+Total Potential 49THC
+49THC+THCa
+Total CBD
+Total Potential CBD
+CBD+CBDa
+Total CEN
+Total CBN
+Full Cannabinoid Profile
+Tetrahydrocannabinol
+Tetrahydrocannabinolic Acid
+Cannabidiol
+Cannabidiolic Acid
+Cannabinol
+THCa
+CBD
+CBDa
+CBN
+Total Active Cannabinoids:
+Pesticide Test Results
+HPLC-Mass...

extracted/summaries/house-oversight-nov/24/house-oversight-024675.txt

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+ACKRELL
+CAPITAL
+CHAPTER III Cannabis Industry Segmentation
+Production Opportunities
+We believe opportunities in this segment include:
+Specialized Production Services. Energy-efficient, Integrated Cultivation Components. Branded Laboratory Test Certification. Efficiencies in Cannabis Cultivation. Production Challenges
+Challenges in this segment include:
+Scaling Cultivation Operations.

extracted/summaries/house-oversight-nov/24/house-oversight-024676.txt

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+ACKRELL
+CAPITAL
+Cannabis Investment Report | December 2017
+Production Outlook
+Due to U.S. federal and international legal restrictions on cannabis commerce, producers currently
+must invest significant capital in potentially redundant facilities located in separate jurisdictions, and
+many large agricultural producers and equipment suppliers that could effectively compete in the can-
+nabis industry are reluctant to enter the market. In the near term, we expect that cultivators will con-
+tinue to...

extracted/summaries/house-oversight-nov/24/house-oversight-024677.txt

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+ACKRELL
+CAPITAL
+CHAPTER III
+Cannabis Industry Segmentation
+APOTHECARIUM
+Dispensary Exterior Views
+elemental
+Dispensary Interior Views
+Customer Interactions
+© 2017 Ackrell Capital, LLC |
+Member FINRA / SIPC
+41
+HOUSEOVERSIGHT024677

extracted/summaries/house-oversight-nov/24/house-oversight-024678.txt

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+ACKRELL
+CAPITAL
+Cannabis Investment Report | December 2017
+Because dispensaries "touch the plant," they must usually obtain a state license. An extensive network of dispensaries across jurisdictions will facilitate the growth of the cannabis
+nause and i are lio are oco ecio a ready sides vin his
+Oregon and Washington, and those that have had medical cannabis laws for a long period of time, such
+as California. For example, according to the Rocky Mountain High-Intensity Drug Trafficking Area,
+as...

extracted/summaries/house-oversight-nov/24/house-oversight-024679.txt

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+ACKRELL
+CAPITAL
+CHAPTER III Cannabis Industry Segmentation
+Distribution Services
+Distribution services is emerging as a prominent subsegment of the cannabis industry; services in this
+subsegment include wholesale distribution of cannabis products to retailers and production inter-
+mediaries, as well as related transportation and logistics services. Historically, a high percentage of
+product manufacturers have sold directly to retail dispensaries, and some of those manufacturers with
+established...

extracted/summaries/house-oversight-nov/24/house-oversight-024680.txt

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+ACKRELL
+CAPITAL
+Cannabis Investment Report | December 2017
+and other distribution intermediaries are subject to county, municipal and other local regulations that
+may restrict or even prohibit distribution activities. Tax Issues Related to Distribution. States and localities that legalize cannabis are focused on the
+potential to generate tax revenue from the industry. Distribution Outlook
+We expect dispensaries across the United States to increasingly seek to provide modern retail experi-
+ences...

extracted/summaries/house-oversight-nov/24/house-oversight-024681.txt

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+ACKRELL
+CAPITAL
+CHAPTER III Cannabis Industry Segmentation
+Consumer Products
+Cannabis may be consumed in many different forms, which fall into three broad categories: flower,
+concentrates and infused products. Cannabis flower
+can also be vaporized and inhaled (using a product known as a "vaporizer"). Concentrates, in turn, can either be vaporized and inhaled or infused into products known as "infused
+products." Infused products may be applied topically, such as lotions and creams, or consumed...

extracted/summaries/house-oversight-nov/24/house-oversight-024682.txt

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+ACKRELL
+CAPITAL
+Cannabis Investment Report | December 2017
+Cannabis Flower
+Cannabis flower, or "bud," is the most popular product among cannabis consumers. Cannabis flower
+is usually green (although some varieties have a purple or orange hue), slightly sticky to the touch and
+spongy in density. BLOOM FARHS
+HEADWATERS
+Do Pesticide and Residual Frei
+Zkittlez
+Hower
+HYBRID
+Branded Cannabis Flower
+There are thousands of different cannabis varieties, each with its own cannabinoid and terpene
+profile...

extracted/summaries/house-oversight-nov/24/house-oversight-024683.txt

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+ACKRELL
+CAPITAL
+CHAPTER III Cannabis Industry Segmentation
+across cannabis varieties and even across flowers from the same plant, which limits the accuracy of lab-
+oratory tests conducted on a sample of plant material. The following chart shows the combined relative sales by category of concentrates for Colorado,
+Oregon and Washington for the three months ended September 30, 2017. Concentrates Sales by Category: Q3 2017
+6%
+18%
+8%
+16%
+35%
+17%
+• Shatter
+• Live resin
+• Oils
+• Other concentrates
+•...

extracted/summaries/house-oversight-nov/24/house-oversight-024684.txt

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+ACKRELL
+CAPITAL
+Cannabis Investment Report | December 2017
+CO, Extraction
+CO, extraction is a process whereby cannabis is introduced into a system of supercritical CO, (COz
+at a pressure and temperature at which it exhibits properties of both a gas and a liquid). Ethanol Extraction
+Ethanol extraction is a method used in a number of industries to extract essential oils and food flavor-
+ings from plants. When used to produce cannabis concentrates, the process involves soaking cannabis
+plant...

extracted/summaries/house-oversight-nov/24/house-oversight-024685.txt

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+ACKRELL
+CAPITAL
+CHAPTER III Cannabis Industry Segmentation
+Infused Products
+Infused products are ingestible products that have been infused with cannabinoids and other active
+compounds from the cannabis plant. Infused products may either be infused with
+concentrates (that are prepared through one of the extraction techniques discussed previously) or pre-
+pared with other infused products, such as cannabis-infused butter (a concentrate prepared by heating
+cannabis in butter to release the active...

extracted/summaries/house-oversight-nov/24/house-oversight-024686.txt

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+ACKRELL
+CAPITAL
+Cannabis Investment Report
+December 2017
+DÉ FONCÉ
+MOUNTJOY
+MOUNTJOY
+MOUNTJOY
+COFFEE
+SPARKLING WATER
+SPARKI ING WATER
+SPARKLING WATER
+MEDICAL CANNABIS
+cloud
+BRIVAL
+1000
+GOOD:
+CBD• TROPICAL TWIST
+-VALHALLA:
+Gummies
+TROPICAL TWIST
+BROWNIES
+Edibles: Chocolate, sparkling water, mints, candies, brownies, gummies
+50
+© 2017 Ackrell Capital, LLC Member FINRA / SIPC
+HOUSEOVERSIGHT024686

extracted/summaries/house-oversight-nov/24/house-oversight-024687.txt

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+ACKRELL
+CAPITAL
+CHAPTER III Cannabis Industry Segmentation
+Capsules and Tinctures
+Capsules are cannabis concentrates with various cannabinoid profiles encapsulated in a gelatin coating
+for easy swallowing. Capsules are digested and metabolized like edibles; typically, the time from swal-
+lowing to onset of an effect is one to two hours. Tinctures are concentrates suspended in an alcohol
+solution and are usually placed under the tongue using a dropper; effects generally begin within 10
+to 15...

extracted/summaries/house-oversight-nov/24/house-oversight-024688.txt

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+ACKRELL
+CAPITAL
+Cannabis Investment Report | December 2017
+Vaporizers and Accessories
+Smoking or vaporizing cannabis flower or concentrates is the most popular method of cannabis con-
+sumption, in part because the effects of inhaled cannabis smoke or vapor begin almost immediately. Accessories used to smoke cannabis include glass, wood or metal pipes; glass or plastic water pipes
+known as "bongs"; and cigarette papers used to roll "joints." A vaporizer is a device that heats cannabis
+flower or...

extracted/summaries/house-oversight-nov/24/house-oversight-024689.txt

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+ACKRELL
+CAPITAL
+CHAPTER III Cannabis Industry Segmentation
+Cannabis Consumers Using Vaporizers
+In addition to smoking and vaporizing devices, an increasing variety of other cannabis-related
+accessories are available, including personal storage and transportation products. Some of these prod-
+ucts focus on safety or discretion, such as childproof containers and smell-proof bags. Other products
+are designed more for style, such as vaporizer pouches and tabletop storage containers intended...

extracted/summaries/house-oversight-nov/24/house-oversight-024690.txt

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+ACKRELL
+CAPITAL
+Cannabis Investment Report | December 2017
+Pharmaceuticals
+Cannabinoid-based pharmaceuticals are drugs containing cannabinoids or cannabinoid-like com-
+pounds that are either derived from natural cannabis or chemically synthesized. A handful of such
+drugs have been approved for use to treat certain medical conditions both in the United States and
+elsewhere. Examples of cannabinoid-based pharmaceuticals that have been approved for use in various
+countries include Marinol,...

extracted/summaries/house-oversight-nov/24/house-oversight-024691.txt

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+ACKRELL
+CAPITAL
+CHAPTER III Cannabis Industry Segmentation
+Epidiolex is an oral formulation of cannabis-derived cannabidiol, or CBD, intended to treat severe
+forms of childhood epilepsy. Epidiolex has not been approved for use in any country, but the drug's
+manufacturer, GW Pharmaceuticals, recently submitted a New Drug Application for Epidiolex to the
+FDA, which is an important step toward FDA approval in the United States. If approved by the FDA,
+Epidiolex would be the first FDA-approved...

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+ACKRELL
+CAPITAL
+Cannabis Investment Report | December 2017
+should seek to develop strong relationships with a large number of dispensary operators, directly or
+through a distributor, in order to obtain preferred shelf placement. FDA Approval: Risk, Time and Expense. Assuming that cannabis-derived drugs will eventually be
+permitted to be sold in the United States, considerable time and expense will be spent by manufac-
+turers to obtain FDA approval and bring approved products to market. Consumer...

extracted/summaries/house-oversight-nov/24/house-oversight-024693.txt

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+ACKRELL
+CAPITAL
+CHAPTER III
+Cannabis Industry Segmentation
+Cannabis Software Platforms
+Business Services
+The business services market includes (i) operational consulting, including facility planning, con-
+struction and security; (ii) financial services, including accounting and payment-processing services;
+(iii) legal, compliance and other professional advisory services; (iv) temporary and full-time staffing
+services; (v) real estate services; and (vi) industry events and conferences. These...

extracted/summaries/house-oversight-nov/24/house-oversight-024694.txt

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+ACKRELL
+CAPITAL
+Cannabis Investment Report | December 2017
+Business Solutions Outlook
+The cannabis industry presents a significant market opportunity for software and services providers
+because of the large number of potential new clients and the need for industry-specific solutions. While this dynamic has
+created a short-term opportunity for some smaller companies, as the regulatory environment becomes
+clearer we expect competition in this segment to increase significantly as large companies...

extracted/summaries/house-oversight-nov/24/house-oversight-024695.txt

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+ACKRELL
+CAPITAL
+Digital Media Opportunities
+We believe opportunities in this segment include:
+Premium Content. We believe that opportunities exist to establish industry-specific publications
+and media platforms for both the business-to-business and business-to-consumer markets that are
+viewed as the legitimate voices of the industry. Digital Media Challenges
+Challenges in this segment include:
+Limited Number of Advertisers. Established digital media companies - such as Facebook, Google, Twitter...

extracted/summaries/house-oversight-nov/24/house-oversight-024697.txt

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+Legal Landscape
+The legal landscape for the cannabis industry in the United States continues to be characterized by
+conflict between federal prohibition and the steady advance of state legalization. According to federal
+policy, Americans can access tobacco, alcohol and prescription drug products that kill thousands each
+year, but they cannot access cannabis because it is a dangerous drug with no currently accepted med-
+ical application in the United States (notwithstanding the federal...

extracted/summaries/house-oversight-nov/24/house-oversight-024698.txt

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+ACKRELL
+CAPITAL
+Cannabis Investment Report | December 2017
+U.S. State Law
+Of the 51 jurisdictions comprising the 50 U.S. states and the District of Columbia, 47 have enacted
+at least one law that permits the manufacturing, distribution, dispensing or possession of cannabis or
+concentrates. Florida and Delaware have both medical cannabis and CBD/limited laws. Every state that has enacted a recreational law has also passed a medical cannabis law. The following map of the United States shows...

extracted/summaries/house-oversight-nov/24/house-oversight-024699.txt

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+ACKRELL
+CAPITAL
+CHAPTER IV U.S. State Cannabis Laws (January 2018)
+Recreational Law
+Alaska
+California
+Colorado
+Maine
+Massachusetts
+Nevada
+Oregon
+Washington
+No Recreational,
+Medical Cannabis
+or CBD/Limited Law
+Idaho
+Kansas
+Nebraska
+South Dakota
+© 2017 Ackrell Capital,
+LLC
+Medical Cannabis Law
+Arizona
+Arkansas
+Connecticut
+Delaware
+Florida
+Hawaii
+Illinois
+Maryland
+Michigan
+Minnesota
+Montana
+New Hampshire
+New Jersey
+New Mexico
+New York
+North Dakota
+Ohio
+Pennsylvania
+Rhode Island
+West...

extracted/summaries/house-oversight-nov/24/house-oversight-024700.txt

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+ACKRELL
+CAPITAL
+Cannabis Investment Report | December 2017
+An exhaustive review of each jurisdiction's laws is beyond the scope of this report; instead we discuss
+issues commonly addressed by each category of cannabis laws. Medical Cannabis Laws
+In 1996, California enacted the first medical cannabis law of any U.S. state, followed in the late 1990s
+by Alaska, Maine, Oregon and Washington. Since the beginning of 2000, 24 more states and the
+District of Columbia have passed medical cannabis laws...

extracted/summaries/house-oversight-nov/24/house-oversight-024701.txt

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+Legal Landscape
+of a single cultivation and dispensing enterprise. CBD/Limited Laws
+From 2014 through 2017, a total of 19 U.S. states enacted CBD/limited laws that generally permit
+possession of small amounts of low-THC/high-CBD cannabis concentrates for use in treating a few
+serious medical conditions. Most CBD/limited laws allow CBD use by children. Many of these laws were enacted in the con-
+text of high-profile stories about CBD treatments for children with severe seizure disorders, and...

extracted/summaries/house-oversight-nov/24/house-oversight-024702.txt

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+ACKRELL
+CAPITAL
+Cannabis Investment Report | December 2017
+limited number of cannabis plants (typically, 4 to 6) for personal use. (Washington is an exception,
+however, and makes personal cultivation a felony unless it is done by a person registered in the state's
+medical marijuana database.) Unlike state medical cannabis laws, which may restrict the form of can-
+nabis products available, recreational laws permit production and sale of most common forms of can-
+nabis products, including a wide...

extracted/summaries/house-oversight-nov/24/house-oversight-024703.txt

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+Legal Landscape
+State governments continue to adjust recreational cannabis regulations in an effort to create favor-
+able industry conditions and address health and public safety concerns. Federal Law
+Current federal law effectively prohibits all cannabis use and all commercial cannabis activity in the
+United States. Producing, selling and possessing cannabis are federal crimes. No cannabis-derived drug
+has ever been federally approved for use in treating any medical condition. Certain...

extracted/summaries/house-oversight-nov/24/house-oversight-024704.txt

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+ACKRELL
+CAPITAL
+Cannabis Investment Report | December 2017
+Federal Laws and Policies Impacting the Cannabis Industry
+Justice
+Department
+Cole Memo
+Controlled
+Substances
+Act
+Bank Secrecy Act
+and Financial
+Transaction
+Laws
+Treasury
+Department
+FinCEN Memo
+Rohrabacher-
+Blumenauer
+Amendment
+Securities
+Law
+DRUG
+AND FOOD
+REGULATION
+Agricultural
+Act
+of 2014
+Federal Laws
+and Policies
+Impacting the
+Cannabis
+Industry
+BANKING
+AND
+FINANCE
+Bankruptcy
+Law
+Food, Drug,
+and
+Cosmetic...

extracted/summaries/house-oversight-nov/24/house-oversight-024705.txt

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+The CSA schedules are numbered I to V. Schedule I substances are subject to the strictest controls,
+and Schedule V substances are subject to the least restrictive controls. A controlled substance is listed
+on a particular schedule according to four factors:
+(i) The substance's potential for abuse.
+(ii) Whether the substance has a currently accepted medical use in treatment in the United
+States.
+(iii) Whether the substance is accepted as safe to use under medical supervision.
+(iv) The degree of...

extracted/summaries/house-oversight-nov/24/house-oversight-024706.txt

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+ACKRELL
+CAPITAL
+Cannabis Investment Report | December 2017
+from being imported into the United States. However, because the production of such non-marijuana
+products ordinarily involves possession of the entire cannabis plant, including parts deemed marijuana
+under the CSA, the CSA effectively prohibits such production in the United States without DEA
+registration. Tetrahydrocannabino/ (THC)
+In addition to and separate from marijuana's listing on Schedule I, tetrahydrocannabinol' (THC) has
+been...

extracted/summaries/house-oversight-nov/24/house-oversight-024707.txt

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+Department of Justice: The Cole Memo
+A memorandum published by the DOJ in August 2013 (Cole Memo) provides guidance to DOJ attor-
+neys and federal law enforcement about prosecuting cannabis-related federal offenses. The Cole Memo
+asserts that marijuana is a dangerous drug, that illegal distribution of marijuana is a serious crime which
+provides revenue to criminal enterprises and that the DOJ is committed to enforcing marijuana-related
+violations of federal law. The Cole Memo also notes,...

extracted/summaries/house-oversight-nov/24/house-oversight-024708.txt

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+ACKRELL
+CAPITAL
+Cannabis Investment Report | December 2017
+Rohrabacher-Farr Amendment
+The Rohrabacher-Farr amendment, first passed by the U.S. The DOJ's interpretation of the Rohrabacher-Farr amendment was rejected by a Ninth Circuit
+District Court in its 2015 ruling in United States v. Marin Alliance for Medical Marijuana, and again by
+the Ninth Circuit Court of Appeals in its 2016 ruling in United States v. The Ninth Circuit
+Court of Appeals held the Rohrabacher-Farr amendment prohibits DOJ...

extracted/summaries/house-oversight-nov/24/house-oversight-024709.txt

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+Legal Relationship between Marijuana and Industrial Hemp
+Marijuana
+Cannabis plant and all parts and
+derivatives except non-marijuana
+Non-Marijuana
+Mature stalks; fiber made from mature stalks;
+oil or cake made from seeds; compounds
+manufactures, salts, mixtures, preparations
+or derivatives of the foregoing parts and
+derivatives (except resin extracted from mature
+stalks); sterilized seeds
+Non-Industrial Hemp
+Cannabis plant and all parts and
+derivatives except industrial hemp
+• Manufacture,...

extracted/summaries/house-oversight-nov/24/house-oversight-024710.txt

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+ACKRELL
+CAPITAL
+Cannabis Investment Report | December 2017
+introduction into interstate commerce" of any drug, medical device, food, tobacco product or cosmetic
+undertaken without the required FDA approval, permit or registration. Drugs
+Generally, the FD&C Act defines a "drug" as any one of the following:
+(i) Any article recognized in the official U.S. Homeopathic Pharma-
+copoeia or National Formulary.
+(ii) Any article intended for use in the diagnosis, cure, mitigation, treatment or prevention...

extracted/summaries/house-oversight-nov/24/house-oversight-024711.txt

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+Legal Landscape
+A drug generally may not be marketed for treating a condition other than a condition for which the
+FDA has found the drug to be a safe and effective treatment; however, most FDA-approved drugs can
+be prescribed by doctors to treat other conditions (so-called "off-label" prescriptions). Cannabinoid-Based Drugs
+Several drugs containing synthetic cannabinoids or cannabinoid-like compounds have been approved
+by the FDA. Syndros, a drug comprised of dronabinol in a liquid solution,...

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+ACKRELL
+CAPITAL
+Cannabis Investment Report | December 2017
+a dietary supplement but not represented for use as a conventional food or as a sole item of a meal or
+the diet. Facilities engaged in manufacturing, processing, pack-
+ing or holding food for consumption in the United States are required to be registered with the FDA. Cannabis-Based Foods and Dietary Supplements
+The FDA has published guidance (most recently updated in August 2017) concluding that (i) the
+FD&C Act does not permit foods...

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+Legal Landscape
+partners and consider many factors, including FDA resources and threats to public health. Bank Secrecy Act and Other Federal Laws
+Regarding Financial Transactions
+Financial transactions in connection with cannabis-related CSA violations may implicate federal laws
+other than the CSA itself, including the federal money laundering statute, the federal unlicensed money
+transmitter statute and the Bank Secrecy Act (BSA). Federal regulations under the BSA require financial...

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+ACKRELL
+CAPITAL
+Cannabis Investment Report | December 2017
+1. Reviewing the license application (and related documentation) submitted by the business for
+obtaining a state license to operate its marijuana-related business.
+3. According to the memorandum, an institution
+should file (i) a "Marijuana Limited" SAR for each customer it believes does not violate state law or
+implicate any Cole Memo priority, (ii) a "Marijuana Priority" SAR for each customer it believes vio-
+lates state law or...

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+ACKRELL
+CAPITAL
+CHAPTER IV U.S. Legal Landscape
+Monthly Marijuana-Related SAR Filings.
+1600
+1400
+1200
+1000
+800
+600
+400
+200
+0
+N
+Q2 2014
+Q4 2014
+Q2 2015
+• Limited
+- Priority
+Q4 2015
+Q2 2016
+• Termination
+Q4 2016
+Q2 2017
+Depository Institutions Making Marijuana-Related SAR Filings
+350
+300
+250
+200
+150
+100
+50
+0
+Q2 2014
+Q4 2014
+Q2 2015
+Banks
+Q4 2015
+• Credit Unions
+Q2 2016
+Q4 2016
+Q2 2017
+Source: Financial Crimes Enforcement Network
+The upward trend in the frequency of marijuana-related SAR filings,...