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Agency evaluation finds limited industrywide impact from cannabis check‑payment rule, recommends continued monitoring
Summary
An internal evaluation found a decline in written warnings tied to check payments after a 2024 rule, but warned that recent violations outside the study window were concentrated with a single licensee; staff recommended a 24‑month follow-up and no rule changes now.
Nick Lavery, deputy director of administration in the licensing division, told the executive management team that an evaluation of the cannabis payment‑flexibility rule shows limited evidence of industry‑wide noncompliance and that monitoring should continue.
The rule, which took effect in October 2024, requires checks used to pay for cannabis to be mailed or delivered no more than one business day after delivery and deposited as soon as reasonably practical and no later than five business days after delivery. The research team examined Enforcement and Education records and external complaints from November 2023 through October 2025 to compare one year before and one year after the rule’s adoption.
Lavery said the evaluation identified warning spikes in July 2024 and January 2025 but that those spikes were driven largely by two licensees whose check practices (including non‑sufficient funds or delayed deposits) produced multiple written warnings. Overall, the number of written warnings fell from 46 in the year before the rule to 29 in the year after, while external complaints remained constant (one before, one after). No violations were issued during the November 2023–October 2025 evaluation window.
Lavery cautioned that 11 violations were issued in November 2025—just outside the evaluation period—and that those violations again related to a single licensee previously warned. "It appears to be a case where a licensee received a warning and continued to be out of compliance, which then resulted in violations," Lavery said.
Based on the findings, staff recommended continued monitoring and a 24‑month follow‑up, and concluded that "it doesn't appear necessary to make any changes to the rule at this time." Lavery emphasized that clearer standard operating procedures and stronger data governance will support future evaluations.
The presentation and the recommendation were informational; no formal board action or vote on the rule change was recorded at the meeting. Staff also identified Captain Tinderstedt and rules coordinator Daniel Jacobs as additional contacts for technical or enforcement questions.
