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Oregon Proposed Cannabis Rules: Mixed Bag

We have been reviewing a raft of Oregon Liquor and Cannabis Commission (OLCC) proposed rules that could significantly affect the Oregon marijuana industry. These proposed rules have implications for licensees, potential licensees and even people doing business with industry like landlords and lenders. Everyone, really.

You can find the first three posts in our series at the links immediately below, each by Jesse Mondry here in our Portland office:

Today, I’ll wrap up the series with the omnibus post Jesse promised, covering everything else of note. Before I dive in, please note: OLCC held a public hearing on the proposed rules yesterday, October 25, but the public comment period won’t close until 12 p.m. PST on October 31. So, get your thoughts in! You can email comments directly to OLCC Rules Coordinator Nicole Blosse.

Proposed OAR 845-025-1170(3): No more services agreements

I’m on record opining that services agreements are a problem in the Oregon cannabis industry. In that post, I offered that services agreements a.k.a. management agreements are a “compliance and litigation hazard” and I mentioned that “we have witnessed an alarming number of compliance issues and outright litigation in the context of services agreements over the years.” OLCC now

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