Safe Harbor CRB Application

Here is how you get signed up for the Safe Harbor Program.

Being a cannabis-related business, you are no stranger to all the details and documentation required to follow state laws for your industry. Connecting you with a financial institution is not that different. We have built an application system that is just as extensive as the one you went through to obtain your license, but that streamlines some of the process to help facilitate things a bit.

We will walk you through the process and help make sure we have all the information and documents we need from you to quickly get you registered and on to the interview stages. The decision will not be instantaneous, but by streamlining the initial steps, we have been able to reduce our processing time. This means you will not sit there for months waiting to move forward.

Step 1: Completing the initial program application

Examples of Documents You May Need:

  1. Any business documents including your By-Laws or Operating Agreement
  2. Your IRS EIN Certification Letter
  3. Your marijuana license or certificate and a copy of the complete application you provided to become a licensee
  4. Your photo ID and a personal resume telling us about yourself and your past work experience
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Step 2: Performing Due Diligence

Examples of Documents You May Need:

  1. Sales records going back up to 6 months
  2. All state reporting and tax records
  3. Internal POS system records
  4. Any investor information (include names of all investors, subscription agreements and your vetting process)
  5. Bank statements for any accounts that may contain money from your CRB. This includes personal and business accounts
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Step 3: Establishing the financial institution partnership

Examples of Preliminary Steps You May Complete:

  1. Face-to-face interview
  2. Site visit of your business location(s)
  3. Completion of a Funds Inventory Log
  4. Review of rules and fees associated with your new account
  5. Review of cannabis specific guidelines
  6. Sign signature card and make initial deposit
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Step 1

Completing the initial program application

Federal guidelines are very clear that financial institutions are responsible for knowing the customers they provide accounts and services to. When that customer is a cannabis-related business (CRB), this requires a deep understanding of the business, the owners and the money invested in and generated from your operations. The first step is completing and signing a Release of Information form. You will then be invited to complete an initial application that is thorough enough to let us determine your current level of compliance and if it is sufficient for us to proceed further. This application requires a small application fee upon submission.

We are not just collecting documents, we are gathering the information we need to make an initial risk determination and decide if we understand your business well enough to move to the next step. This will provide the framework for our due diligence that follows.

What it involves

The bulk of this first step will involve you completing an application. The process is a bit lengthy as it is comprised of a few more than 150 questions. Not to worry though, you will be able to save your progress. We do not expect you to complete it in a single sitting. Some of the questions will require you to upload specific documents. The more of those you have ready, the quicker you will be able to complete your application. Safe Harbor Program representatives will be available to answer questions and provide help if you need it.

Once your application is complete, it will be reviewed by a member of the Safe Harbor Program team who will then contact you to set up a series of further interviews. These will likely be a combination of phone and online video interviews that will help us get a better feel for you and your business for purposes of making our initial assessment.

How to prepare

Gather all the documents that relate to you setting up your business. We recommend scanning them ahead of time and saving them to the computer you are going to use to complete the application which will make things easier.

Documents you should have at the ready:
  1. Any business documents including your By-Laws or Operating Agreement
  2. Your IRS EIN Certification Letter
  3. Your marijuana license or certificate and a copy of the complete application you provided to become a licensee
  4. Your photo ID and a personal resume telling us about yourself and your past work experience

Step 2

Performing the due diligence

This is where the deep dive into your business operations occurs. The Safe Harbor team will be very hands-on at this point. An assigned Safe Harbor representative will be working closely with you to develop a sufficient understanding of your operations until we feel comfortable moving to the final step, which would be connecting you with a financial institution and establishing your account.

The documents and data we gather through our due diligence process will be carefully cultivated to provide an easy way for our financial institution partners to understand your business as they review you as a potential customer. It is the thoroughness of our due diligence process that makes it feasible for financial institutions to provide services to CRBs.

What it involves

An inspection of your operations

We will perform a full review of your business including ownership, account authorities and operational structure. We will complete background checks on all owners, account owners and signers on the account. Several levels of operational review will be involved and will be dictated by the complexity of your organization.

An examination of your financials and business plan

We will also closely analyze your financial information and business operating plans, which will provide insight into your financial dealings and your prospective banking habits. We use this to help our Financial Institution Partners understand where a potential customer has been financially, and understanding where they intend to go.

How to prepare

We will be requesting a large amount of information at this stage. The more tax and financial documents you have at the ready that provide insight into your cash on hand, the smoother the process will go. If they are not already available and organized, you should track down all documents that relate to your business’ historical performance, its earnings and sales, any documents related to funds you received from investors, any lines of credit that exist and the sale of any assets.

Documents you should have at the ready:
  1. Sales records going back up to 6 months
  2. All state reporting and tax records
  3. Internal POS system records
  4. Any investor information (include names of all investors, subscription agreements and your vetting process)
  5. Bank statements for any accounts that may contain money from your CRB. This includes personal and business accounts

Step 3

Establishing the financial institution partnership

Finally, the difficult part is over, now is where you see results. This step still takes a little time to complete though, as it is involves making a smooth transition into what will be your ongoing relationship with your Safe Harbor financial institution.

Due to the complexity of the business structure, extra caution is exercised to make sure all the proper reviews are completed, all the right forms are filled out and the initial deposit is properly handled. Patience and attention to detail will be your best approach as a lot of ground will be covered.

What it involves

Once the due diligence is complete and a determination to move forward has been made, the Safe Harbor team will present your business to participating financial institutions that fit your business and your needs. Once they have reviewed your file and accepted you as a potential banking customer, you will meet directly with the financial institution to complete the remaining documentation and open your account. This may include any or all of the following:

  1. Face-to-face interview
  2. Site visit of your business location(s)
  3. Completion of a Funds Inventory Log
  4. Review of rules and fees associated with your new account
  5. Review of cannabis specific guidelines
  6. Sign signature card and make initial deposit

When a financial institution selects you, they will want to interview you before proceeding. While they have already reviewed the results of our due diligence, this face-to-face interview will likely cover many of the same topics. They need to understand your business model, your ownership and your monetary transactions for themselves as they are trying to determine their level of comfort in establishing a long-term account relationship with you and your business.

The financial institution will have you complete a Funds Inventory Log, which will be used to validate your funds on hand and determine if they are reasonable based upon the business you do and how your operation is run. They will also be doing site inspections of your operations. A visit will be scheduled for each site or location. If your business holds both a dispensary and cultivation license, separate inspections will be required for each.

Once the financial institution verifies the due diligence and feels comfortable that they know you as a customer, they will proceed with opening your account. At this point, your initial deposit will be coordinated, any outstanding setup fees will be collected, the specifics of your account will be reviewed and an introduction to the person at the financial institution who will be your point of contact going forward will be made.

How to prepare

At this point you have provided all documents and information that relate to your business. The best preparation for this phase is simply keeping in mind there is a lot at stake for all parties involved as you get ever so close to securing financial services for your business. Be ready for all the back and forth of forms and documents that will occur. The more efficiently you handle them, the easier this step will be completed. Think about establishing a process ahead of time and committing to it throughout.