A paper written by the Cannabis Regulators of Color Coalition (CRCC) was published by the Ohio State University Moritz College of Law on Aug. 12. The paper, entitled “Not a SAFE Bet: Equitable Access to Cannabis Banking, An Analysis of the SAFE Banking Act,” analyzes the Safe and Fair Enforcement Banking Act (SAFE), and includes numerous recommendations for improvement.

Authors Cat Packer, Shaleen Title, Rafi Aliya Crockett, and Dasheeda Dawson state that the SAFE Banking Act isn’t enough in its current form. “But unfortunately, SAFE, as written, is unlikely to result in equitable access to financial services,” they wrote in the study abstract. “This paper summarizes the bill, analyzes why it would fall short of its purported goals, and makes recommendations to improve the bill.”

“SAFE would address only the legal and regulatory consequences potentially faced by financial institutions for providing services to the cannabis industry,” the authors wrote in their executive summary. “Without additional legislative amendments to directly address challenges related to fair and equitable access to financial services, small and minority-owned cannabis businesses that currently have inadequate access to banking services or loans are likely to continue to be denied the full breadth and depth of services offered to others.”

The authors compiled 10 recommendations that could help improve future reform of cannabis banking (check out the full explanation for each recommendation here.) In summary, these recommendations cover a thorough collection of topics of improvement, such as redirecting Internal Revenue Service code 280E funds, expanding requirements for anti-discrimination laws, identifying best practices for federal banking regulators, and much more.

The authors concluded that although a cannabis policy gap has developed, now is the time to

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