The New York Cannabis Control Board (“CCB”) held a
momentous meeting on November 21, 2022 wherein it
continued to issue more conditional cultivation, processing, and
dispensing licenses, but, perhaps more importantly, proposed for
issuance the first set of adult-use cannabis regulations that will
govern all of the non-conditional licenses issued to date.
New York, both through the CCB and the Office of Cannabis
Management (“OCM”), has created a marketplace that is
certainly not free of complexity. Indeed, CCB had initially issued
hundreds of cultivation licenses without any regulatory guidance,
only to issue written guidance (not formally promulgated
regulations), halfway through the cultivation season that included
strict rules regarding cross-ownership and lending opportunities
for those with direct and indirect interests in licenses, i.e.,
what New York refers to as true parties of interest. The same can
be said for the Conditional Adult-Use Retail
