As we pass the halfway mark of 2022, it's a good time to
reflect on what has happened, or not happened, with respect to the
legal framework for the provision of financial services to
marijuana-related businesses (MRBs). In our review, the answer to
this question is "not much," or put differently, the more
things change, the more they seem to stay the same. While advocates
in Congress continue to push for reform, the prospect of
comprehensive legal reform remains uncertain, and the federal
government has taken few, if any, additional steps to provide
guidance to MRBs or financial institutions seeking to provide them
with basic banking services.
Still, even against this uncertain backdrop, more and more
financial institutions are providing banking, lending, and even
payments services to MRBs in states in which marijuana has been
legalized. This expansion is the product of continued legalization
of marijuana at the state level (Arizona, Montana, and New Jersey
in 2020),
