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                                                                Dustin Eide is CEO at CanPay, a debit payment platform
               The very point of sale                           for the cannabis industry. The CanPay payment network
                                                                launched in November 2016 and currently serves over
                                                                300 dispensaries and recreational shops across 19 states
                                                                while continuing to expand. "We're legitimately serving
                                                                the cannabis industry, and tens of thousands of consumers
                                                                who use our app no longer have to go to the bank before
                                                                visiting a dispensary and find transactions are quicker,"
        Transparency is the                                     he stated. "We only allow companies that operate within
                                                                FINCEN guidelines to accept CanPay. Our funds are not
        new currency                                            commingled, and transactions are traceable and trackable."

                                                                CannaTrac Technology Inc. deploys CannaCard, a HIPAA
                                                                compliant cashless payment platform designed to provide
        By Dale S. Laszig                                       consumers and merchants with ease of use and financial
                                                                institutions with transparency and due diligence to
                 he concept of transparency has been coming to   satisfy regulatory requirements.  Thomas Gavin IV, the
                 the fore in news, webinars and panel discussions   company's CEO and vice chairman, recalled a visit to
                 across numerous business sectors, including    a cannabis dispensary where transactions were being
        T merchant services. I've asked industry leaders        processed as tire sales. "Inaccurate or misleading receipts,
        how to leverage this trend. Some see it as a core value; oth-  where transactions are being charged as retail or ATM
        ers say it's mostly aspirational, since achieving full trans-  withdrawals, make it difficult for end-users and banks to
        parency is a nearly impossible goal.                    get behind this market," he said.

        Anand Inamdar calls transparency "the new currency      Equipment leasing and finance industry
        in the modern workplace." His Jan. 10, 2017, blog post
        titled "Building a winning team with agile performance   The $1 trillion equipment leasing and finance sector is
        management," defines transparency as being clearly      complex and evolving, as next-gen technologies transform
        perceptible. Transparent managers instill trust and improve   legacy systems into agile service offerings. The Equipment
        team performance, he noted. "When there is a sense of trust   Leasing and Finance Association created its 6 Principles of
        between the manager and the team member, performance    Fair Business Practices in 2006. Transparency is an integral
        [review] discussions are more inclined towards making the   part of these standards, which model industry best
        process [a] win-win for everyone involved," he wrote.   practices, as follows:

        Cannabis industry                                         ELFA  members  believe that all  business agreements,
                                                                  arrangements and transactions should be conducted
        Transparency is mandated in the cannabis industry,        with transparency with respect to the roles and
        where participating merchants are deemed high risk        responsibilities of all parties. Full disclosure in and
        and have restricted access to traditional banking and     clarity of transaction documentation is a key element of
        merchant  services  channels.  Fintechs  are filling that gap   such transparency.
        with innovative processing systems that accommodate
        disclosure requirements. In a panel discussion at the 2019   We believe that all member companies should conduct
        Mobile Payments Conference, three leading cannabis        their business relationships with suppliers and
        service providers reviewed how next-gen payment           customers in a fair and reasonable manner and should
        solutions  help  address  regulatory  requirements  and   comply with the letter and spirit of applicable laws and
        improve the customer experience.                          regulations.
                                                                  We believe that all member companies should encourage,
        Brianna Moriarty, partner development manager at Star     to the extent reasonably practical, that all parties to
        Micronics, pointed out that accurate reporting is a baseline   a business agreement, arrangement or transaction
        requirement for achieving and maintaining compliant       (including members' customers and suppliers) operate
        cannabis businesses. Star Micronics POS solutions help    consistent with these Principles.
        merchants simplify compliance by validating customers,    We believe that it is incumbent upon members, and the
        keeping transactions within state regulated limits, and   Association on members' behalf, to promote education
        providing compliant receipts and reporting, she stated.   and  awareness  such  that  all  parties  to  business
                                                                  dealings consult, where necessary or appropriate, their
        "For the industry as a whole, not having transparency in   professional advisors.
        payments makes it more difficult for banks to accept money,
        comply with KYC and legitimize cannabis transactions,"    We believe that business transactions and related
        she said. "Inaccurate receipts may also raise consumer    activities should be conducted with integrity and the
        concerns and increase chargeback risk."                   highest ethical standards.

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