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        Workarounds emerging                                    "When customers are made aware of our ability to comply
                                                                with FinCEN, and avoid the problems spelled out [by DOJ],
        In addition to the dispensaries in Hawaii, CanPay has   they tell us there is no alternative: we're it," said Medical
        contracts with dozens of legal cannabis dispensaries    Cannabis Payment Solutions CEO Jeremy Roberts. The
        in California, Colorado, Florida, Maine, Oregon and     company said it ultimately wants to provide an end-to-end
        Washington. The company works with 20 financial         cannabis business solution, not just support payments.
        institutions, mostly community banks and credit unions,
        through its closed-banking feedback loop. All rely on   Huge potential, limited ISO/MLS opportunities
        cannabis banking platforms designed to comply with the
        FinCEN-DOJ guidance, Eide said.                         The market for legal sales of cannabis products (medicinal
                                                                oils, pot, cannabis-infused edibles, etc.) is huge and
        In Hawaii, CanPay works with Safe Harbor Private        growing. North American consumers spent $6.7 billion on
        Banking, a unit of Partner Colorado Credit Union. The   legal cannabis products in 2016, according to The Arcview
        Arvada, Colo.-based credit union developed a platform to   Group, a cannabis investment and market research firm.
        bank cannabis businesses in compliance with the FinCEN-  The website Marijuana Business Daily estimates total
        DOJ guidance to serve customers in its home state. The   annual demand for recreational cannabis in the United
        Safe Harbor unit was launched in July 2017 to market the   States exceeds $45 billion.
        platform more widely.
                                                                In Colorado, retailers racked up a collective $1.02 billion
        "We want to expand the cannabis program nationally and   in sales of medical and recreational cannabis products
        help other financial institutions solve the safety issue of   during the first eight months of 2017, adding $162 million
        the unbanked cannabis industry," said Safe Harbor CEO   in taxes and fees to state coffers. California officials said
        Sundie Seefried. As of July, Partner Colorado said it had   they expect legal cannabis sales there to top $7.6 billion
        deposited, validated, reported and monitored  over $1   a year by 2020, adding an estimated $1 billion a year in
        billion in sales from cannabis businesses in Colorado.   revenues to state coffers. Arcview, meanwhile, forecasts a
                                                                27 percent combined annual growth rate in legal cannabis
        Eide conceded CanPay's mobile debit app is not a perfect   sales through 2021 when it expects legal pot shops in
        solution. "It's as close to the experience of paying with   the  United  States  and  Canada  to  collect  $22.6  billion  in
        a credit or debit card as we can get without violating   revenues.
        any  [government  or  card  association]  prohibitions,"  he
        said. Should the federal government relieve cannabis of   So are there opportunities for ISOs and MLSs to tap into
        its Schedule 1 status, CanPay has the technologies and   this revenue stream? Yes, but not many, and those that exist
        processes in place to support all manner of retail cannabis   may not be lucrative, or technically legal. "There are a lot
        payments.                                               of folks out there misrepresenting themselves," said one
                                                                MLS. This MLS, who asked not to be identified by name,
        Wil Ralston, President of SinglePoint Inc. said his company   said he considered working with offshore processors to
        is similarly positioned. "We already have all the pieces in   support cannabis dispensaries but was scared off by what
        place to get a credit-debit card solution up and running,"   he saw as a lack of transparency.
        Ralston said. In the meantime, Seattle-based SinglePoint
        is test-driving SingleSeed Payments, a mobile solution for   Assessing offshore options, Kolb said, "There are a lot
        paying at cannabis dispensaries that uses a proprietary   of wild cowboys out there." And Ralston pointed to the
        bitcoin exchange. "We hope to start processing by mid-  added cost of working with offshore processors, including
        January," Ralston said.                                 international transaction surcharges. "It's not something I
                                                                even suggest people do," he said.
        A mobile technology company, SinglePoint has been
        acquiring technologies and companies that eventually will   Several experts believe the traditional ISO/MLS business
        support a soup-to-nuts platform for cannabis businesses.   model of making money by marking up the rates of
        "The overall goal is to have a fully integrated solution for   upstream partners doesn't work well in a market like
        businesses to manage their day-to-day operations from   cannabis, where risks are deemed high and costly. "It's
        beginning to end," Ralston said.                        always going to be high risk," Ralston said. "They [cannabis
                                                                businesses] are still going to pay high rates."
        Medical Cannabis Payment Solutions, based in Cheyenne,
        Wyo.,  has  another  approach.  It's  readying  a  closed-  Kolb agreed, stating, "There's really not much profitability
        loop system for cannabis payments that customers can    there when you start cutting into the pie."
        access by card or mobile app and that abides by federal
        guidance. The card/app can be funded with credit or debit
        cards, through a checking account link or using bitcoins.
        Participating dispensaries receive funds via ACH or wire
        transfers.

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