The Office of Cannabis Business Regulation within the Rhode Island Department of Business Regulation is currently accepting applications for six new Compassion Center licenses.  One license will be awarded for each of the six zones delineated in the license application materials, and applicants must apply for a license in a specific zone.  The application period commenced on July 17, 2020 and will remain open until 3 p.m. on December 15, 2020.  The license application materials can be located here and the nonrefundable application fee is $10,000.

Interested parties may submit questions to the Department until the application deadline.  However, the application materials make clear that, for questions received after 4:00 p.m. on December 1, 2020, the Department may not respond prior to the December 15, 2020 application submission deadline.  The FAQs posted by the Department in response to questions already received from interested parties provide helpful insights into the Department’s approach to the current application cycle and also the Department’s interpretations of its own regulations and application materials.  For example, one FAQ clarifies that “a person or entity cannot be an ‘interest holder’. . .  with respect to more than one applicant/application for a compassion center license per zone.”  Similarly, another FAQ confirms that “an applicant who is approved and selected for licensure as a compassion center will only be licensed to conduct compassion center operations at the proposed location set forth in the application, [but] if that applicant already holds a cultivator license under the Act, the applicant will be permitted to continue their existing licensed cultivator operations … at that previously licensed cultivation location.”

Finally, the application materials highlight several key exhibits which must be included within each application in order for the application to be deemed complete.  They include: A) a disclosure of any material financial interests or control in another compassion center, cultivator, cooperative cultivation or other marijuana establishment licensee; B) evidence of appointment of a Compliance Officer which shall include the applicant’s legal and operational compliance plan; C) a Business Plan; D) a Security and Safety Plan; E) an Operations Manual; and F) a description of the proposed Licensed Premises, including street address, plat/lot number and zoning district.  The Department will treat incomplete applications as deficient and will not review or evaluate such applications.  The Department also will not refund the application fee for incomplete applications.