Bank Directors Seminar, Coeur d'Alene, ID, September 15-17, 2019

Banking Marijuana • As of Sept. 2019, 33 states (and DC) have comprehensive medical marijuana programs and 11 of these states (and DC) allow for the recreational use of Marijuana. • Most states in the "not permitted" camp do allow for low-THC CBD. Only a few states (NE, SD, and ID) have no access of any kind. • Issues: Access to banking services, Section 280-E of US Tax Code, Access to capital, insurance, bankruptcy, Farm Bill's "legalization" of hemp • Pending Legislation: SAFE Act, STATES Act • This summer, CSBS released public job aid for examiners on marijuana banking Marijuana Banking Panel o Public safety concerns related to cash o 35 states, monthly meetings

55

Debt Collection • State regulators license and supervise debt collectors under state debt collection laws • 2019 Comment Letter Made the Following Points: o The Bureau should clarify the impact of the proposed rule on disclosure requirements imposed by state debt collection laws o State law disclosures should be prominently referenced and displayed on all types of debt validation notices o The Bureau should provide further clarification on the ways a consumer can opt out of an electronic communication; and o The Bureau should apply the proposed limit on call attempts by a debt collector on a per consumer rather than a per debt basis

56