Cole Memo Rescinding

AG Jeff Sessions is rescinding the Cole memo. This has direct and immediate consequences for issues related to banking as the federal banking guidelines for cannabis businesses are based on the Cole memo. States with adult-use laws are now significantly more exposed to federal intervention as they are not covered by the Rorahbacher-Farr amendment. Medical states are also more vulnerable.

So, what’s going on?

Does Sessions know Trump is getting rid of him so trying to get his shots in before he’s gone? Is the move related to immigration and/or prisons? Following close on the heels of California legalization, is it related to the entrance of such a major cannabis market on the world stage? Is it random? Did Trump know? Is it  aimed at serving as a distraction from the Michael Wolff book on Trump? Does Sessions know he can’t stop progress on the cannabis front, but he will slow it by scaring off investors?

Could it provoke in Congress the recognition for the need for legislation to protect state programs and markets?

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