CSA Updates Guidance for Issuers with U.S. Marijuana Operations or Assets
It was unclear how the Canadian Securities Administrators (“CSA”) would react to the rescission of the Cole Memorandum by Attorney General Jeff Sessions, we recently discussed, given that Canadian issuers with U.S. assets or operations rely on the regulatory framework created by each State based on the guidance and enforcement priorities set forth in the Cole Memorandum.
Sessions Rescinds The Cole Memorandum
In the summer, the State Legislature of California passed California Senate Bill 94 which effectively consolidated the two separate licensing regimes for medicinal cannabis regulations (the Medical Cannabis Regulation and Safety Act (“MCRSA”)) and recreational cannabis regulations (Adult Use of Marijuana Act (“AUMA”)) in the State of California.