Our Board of Directors was hand selected by our Legacy Operator Members to guide our organization. Although the Board does not consist of all Legacy Operators, we believe that it reflects our Diversity and Aspirations to be a sound voice for the Legacy Operator Community. Our Board of Directors Consists of Michael Abramson, Vladimir Bautista, Jesse Campoamor, Dorian Harrington, and Josh Tepperberg. Our Advisors include long time Activist Steve DeAngelo and Cannabis, Agricultural, and Dietary Supplement Attorney Scheril Murray Powell, Esq.
“To unlock the opportunity for experienced legacy operators to enter the legal cannabis industry and contribute to the elevation of the cannabis industry with regards to inclusion, safety, product quality, and innovation.
UNLOC recognizes the history of legacy operators. They are forever woven into the tapestry of Cannabis History and have taken great risk to personal freedom to build the cannabis industry that is accepted today…it would not exist otherwise.
UNLOC empowers and transitions legacy operations into the legal cannabis industry equipped with a supportive network of resources that will ensure their success.
UNLOC is committed to demonstrating to government agencies, corporate cannabis participants, and the public that legacy operators are an asset to the industry.
UNLOC is determined to destigmatize what legacy operators are traditionally characterized as, and establish legacy operators as innovators, pioneers and key stakeholders of the developing legal Cannabis industry.
UNLOC advocates for the Cannabis plant and believe that through its healing power Legacy Operators have eased suffering and enhanced the quality of life for millions of people.”
UNLOC, Inc. PUBLIC COMMENTS
INTRODUCTION The MRTA Act that was signed into law in 2021, makes it clear that the Legislators intended for Legacy Operators to be welcomed into the Legal Industry in order to correct the multiple decades of harm that was caused due to over policing and erroneous laws restricting access to Cannabis. The Unified Legacy Operators Council (“UNLOC,Inc.” or “UNLOC”) recognizes the priority being given to justice-involved individuals and Legacy Operators as an attempt to remedy the harms of the past. UNLOC supports the intent, however we have some critical recommendations that may not have been considered or taken into account. We are available to work with New York’s Cannabis Control Commission and will continue to offer feedback as needed. Please consider UNLOC to be a resource for the NY Cannabis Control Commission. UNLOC is a vetted group of law-abiding citizens and Legacy Operators that believe Cannabis should never have been considered a controlled substance. Our vetting process includes validating the following criteria 1) Long Term involvement in the Legacy Market selling THC products (longer than 5 years), True New York Legacy Market Involvement, and earning the majority of their income from the Legacy THC Cannabis Market).MRTA in Article 1 explicitly says that “Existing laws have also created an illicit market which represents a threat to public health and reduces the ability of the legislature to deter the accessing of marihuana by minors.” If this is how the State of New York feels about having a legacy market operating simultaneously with the Legal Market, then welcome us into the industry with support and encouragement. We do not see ourselves as being a threat to public health, we see ourselves as brave visionaries that saved lives and improved the quality of life for many before the rule makers woke up to the healing benefits of cannabis as medicine. However, we are prepared to comply with State law with regards to product safety and control. We have much to contribute and we want to contribute to building a robust and inclusive cannabis industry. MRTA also states that: “The intent of this act is to regulate, control, and tax marihuana,heretofore known as cannabis, generate significant new revenue, make substantial investments in communities and people most impacted by cannabis criminalization to address the collateral consequences of such criminalization…reduce the illegal drug market and reduce violent crime, reduce participation of otherwise law-abiding citizens in the illicit market, end the racially disparate impact of existing cannabis laws”. We as UNLOC have the following feedback on the draft regulations based on our experience and expertise in commercializing cannabis efficiently and in a way that ensures public safety. We are confident that if our products are put next to legal cannabis product that we will test as compliant and free of contaminants. The Charge Types to Be Considered Justice Involved UNLOC recognizes that in the illicit trade of cannabis, the related criminal charges/criminal penalties suffered may not explicitly state marihuana or cannabis in the title, therefore this definition of Marihuana-related offense is flawed. “(r) Marihuana-related offense means a marihuana or cannabis offense defined under article two hundred twenty-one of the penal law prior to its repeal, any offense under article two hundred twenty or section 240.36 of the penal law prior to the effective date of article two hundred twenty-one of the penal law, where the controlled substance involved was marihuana, or any offense that is eligible to be sealed or expunged pursuant to Chapter 131 of the Laws of 2019 or the Act.” We believe that there are other related charges relevant to legacy operators and we should expand to include Resisting Arrest, cannabis related Child endangerment/Custody removal, Civil Forfeiture, Criminal Forfeiture, or related charges. We also would like the Regulators to consider the inclusion of New York residents/ Legacy Operators that may have been arrested out of State while transporting Cannabis. The definition of justice-involved is too narrowly focused and contrary to the Legislative Intent of MRTA We believe that although the Cannabis Control Commission is intending to remedy the significant harm caused to legacy operators and “justice-involved” individuals, that in execution the objective will not be accomplished. The current regulations will allow for a wealthy privileged person who has a single marijuana related charge, but did not take part in the previous commerce of cannabis to be eligible for a priority license. It also does not provide sufficient opportunity for those who were actively involved in the commerce of cannabis to be eligible because they were never charged for a crime or had good legal counsel. There needs to be a revision to the justice involved definition to properly validate true operation in the legacy market. The New York Cannabis Social Equity Fund, Use of The Fund and Lending Terms It has been indicated that the Fund may be used to purchase dispensing locations for the licensees to operate with design by those individuals/contractors that are not experienced in the Cannabis Industry. This approach is not optimal for creating a free and open market. Licensees should be able to determine their site design of choice. These contracts should be given to companies with diverse ownership and equity considerations. The placement of a dispensary is critical for its success. Our fear is that the locations will not provide sufficient opportunity for foot traffic, marketing, and access to cannabis consumers. Also, it creates a monopolistic environment for the State with regards to lending terms. Licensees should be free to select dispensing locations which will optimize commerce and profitability. Also, we would like to see the FUND be used to guarantee traditional and private lending of the licensee’s choosing. Finally, the fund should be used to provide skills training, legal support, and other knowledge gap filling measures. By providing legal support and contract review, it will mitigate the issue of Licensees being duped into predatory contracts. Proof of funds, Profitability and Business Acumen Legacy Operators should have the requirement to have two years of profitability and/or financial statements waived. It is unrealistic to expect Legacy Operators/ Justice Involved individuals to show audited financial records. In addition, the requirement of 10 percent ownership of a profitable entity registered with the Secretary of State is misplaced and unnecessary. We believe that this is an attempt by the Cannabis Control Commission to get comfort in the licensee’s ability to run a business. This proof of business acumen can take place in a variety of ways, and they are not all tied to “ownership”. Many people run businesses that do not belong to them and not all recognized entrepreneurs are registered with the Secretary of State. A narrative detailing business experience in an ownership, management, or supervisory role would be more appropriate and sufficient to demonstrate business skills and provide an indicator of potential success. There should be an opportunity for an “essential partnership” or training or avenue for people who ran businesses without official titles of businesses, ex: Managers, Executive Assistants, etc. Finally, because of the risk of Money Laundering charges/allegations, Legacy Operators have been discouraged from participating in legal business opportunities. Therefore, although they have significant business experience, they will not meet the narrowly focused requirements from the Regulations of two years of profitability and ten percent ownership. Excess Taxation will discourage participation in the Legal Industry The taxation scheme being considered needs to take into account that if the taxes are too high, it will drive up the cost of cannabis in a way that will discourage consumers from purchasing from legal cannabis sources. It will also discourage Legacy Operators from joining the Legal Cannabis industry out of fear that they will not be profitable. In California, this issue was so extreme that some cannabis licensees would say that “they cannot even afford to buy their own cannabis” and would continue to purchase from illicit/legacy sources just like other consumers.
SUMMARY In summary, UNLOC, Inc. was founded to contribute to the State of New York by actively participating in the rule making process and representing the voices of the thousands of Legacy Operators in New York that have been relegated to the shadows although they understand the commerce of cannabis better than anyone else in the State. We want to encourage the Cannabis Control Commission with regards to their intentions of honoring MRTA’s mandate of providing remedies for those most significantly harmed by the War on Drugs. However, we want to contribute viable solutions that will ensure fairness of license issue, and make sure that legislative intent of MRTA is not frustrated with unnecessary requirements that are not related to prediction of Licensee Success. We encourage the Cannabis Control Commission to seriously consider the above-mentioned comments with regards to expanding the charge types to be considered justice-involved, The definition of justice involved allowing for non-legacy operators to get the priority license benefit while true Legacy Operators are locked out of the opportunity, a reasonable approach to taxation, use of the Cannabis Social Equity Fund, and the restrictive proof of profitability/proof of business ownership requirements.
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UNLOC INC will Be presenting at NECANN Albany, NY on August 26-27 https://necann.com/new-york-convention/
09:00 am – 05:00 pm
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09:00 am – 05:00 pm
09:00 am – 05:00 pm