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Minnesota OCM can deny or block a cannabis-license investment when an investor is an owner, manager, officer, director, general partner, controlling person, or other person responsible for the business. That person fails the criminal, regulatory, ownership, or disclosure requirements. The most serious criminal disqualifiers are specified drug-trafficking offenses, human or labor trafficking, fraud and financial crimes, certain cannabis-sale convictions after August 1, 2023, adulteration, and electronic-data theft; a disqualifying felony is permanent unless OCM grants a variance. A person who merely makes a properly structured passive investment may be excluded from the statutory definition of “true party of interest,” but that exclusion should not be treated as automatic protection from review. Minnesota’s background-check statute and rule broadly reach owners and people responsible for conducting the entity’s affairs, while OCM also requires disclosure of investment sources and true parties of interest. People OCM Reviews The criminal-history requirement reaches every cannabis-license applicant or holder and, for a business entity, every person responsible for conducting its affairs, including owners, cooperative members or directors, managers, and general partners. State and national records may be checked through the BCA and FBI. Every officer, director, manager, and general partner must also satisfy the general ownership qualifications in Minnesota Statutes section 342.16. These include being at least 21, not being an OCM or relevant state-agency employee, not being a licensed peace officer, not having a Minnesota or out-of-state cannabis authorization revoked, complying with cannabis tax and OCM information requests, and having no recent confirmed willful labor violation covered by the statute. Criminal Disqualifiers Category Conduct covered Normal effect Serious noncannabis drug offenses First- or second-degree controlled-substance crimes; possession of substances with intent to manufacture methamphetamine; counterfeit drugs; causing great bodily harm through drug distribution; using drugs to injure or facilitate crime; and sale of cannabis to a minor Disqualifying; permanent if the offense is a felony, subject to a variance. Trafficking Labor trafficking; sex trafficking and promotion-related offenses; trafficking-related document offenses Disqualifying; permanent if felony, subject to variance. Fraud and financial crimes False tax statement, bribery, perjury, concealing criminal proceeds, insurance fraud, theft of public funds, false government claims, medical-assistance fraud, forged instruments, specified notary and lottery fraud, commercial bribery, and any crime having fraud, deceit, or embezzlement as a required element Disqualifying; permanent if felony, subject to variance. Post-legalization cannabis sales Cannabis-sale crimes under section 152.0264 for convictions after August 1, 2023 Five years from conviction under Rule 9810.1001. Other offenses Adulteration and computer or electronic-data theft Disqualifying; permanent if felony, subject to variance. Attempts and conspiracies Attempting or conspiring to commit one of the listed crimes Treated as disqualifying when the underlying crime is listed. Equivalent federal/out-of-state crimes Conviction whose elements match a listed Minnesota crime Treated as disqualifying. Not every felony is automatically disqualifying merely because it is a felony. Rule 9810.1001 supplies the operative offense list, although its catchall for an offense in which fraud, deceit, or embezzlement is a necessary element can capture crimes bearing different titles in Minnesota or elsewhere. A violation of Minnesota Statutes section 152.025 cannot be made disqualifying under section 342.15. Certain successfully completed stays of adjudication and an eligible expunged conviction under former section 152.09 are also excluded by the rule. Variance Possibility A permanent felony disqualification is not necessarily the final word. After at least five years from release from incarceration or conviction, whichever is later, the person may ask OCM to make the disqualification nonpermanent by showing that permanence does not serve the public interest. OCM’s factors include the proposed role, seriousness and circumstances of the crime, age at the time, whether it was isolated, rehabilitation, conduct in custody or the community, treatment or education, recommendations from supervisors or mentors, and community benefit from licensing the applicant. Noncriminal Barriers OCM may also disqualify based on a substantiated civil or regulatory violation that creates a public-health or safety risk. A prior disqualification, revocation, or prohibition imposed by another state’s cannabis authority is independently disqualifying under the rule.revisor.mn An unlicensed chapter 342 violation followed by an OCM administrative order after August 1, 2023 carries a five-year disqualification from the order date under the rule. Current statutory requirements also bar an applicant whose Minnesota or out-of-state cannabis authorization was previously revoked. Investor Structures A true party of interest generally includes LLC members and managers, partners, privately held corporate stockholders, officers and directors, people in layered ownership structures, anyone entitled to cannabis-business revenue or profit, and anyone with control. All true parties must be disclosed, and the business must disclose the source of invested money before investment. A passive ownership interest meeting the federal passive-investment definition is excluded from “true party of interest.” Fixed-rent landlords, ordinary salaried employees without ownership or control, qualifying consultants and service providers, and financial institutions are also excluded, but a lender expecting repayment may be a “financier” whose funding source still must be disclosed. A financier cannot take ownership, control, revenue, gross-profit or net-profit participation, or another profit-sharing right in return for funding unless the directly involved financier is disclosed to OCM as a true party of interest. Attempts to label equity, control, or profit participation as a “loan” will therefore not avoid disclosure. Other barred investors A licensed peace officer an OCM employee an employee of another state agency regulating chapter 342 cannot qualify in the roles governed by section 342.16. A health-care practitioner who certifies patients’ qualifying medical conditions cannot hold a direct or indirect economic interest in a cannabis business or serve as its cooperative member, director, manager, general partner, or employee. OCM can also reject ownership changes that add an owner who is ineligible under the background-check process, violate true-party-of-interest provisions, or reduce required social-equity ownership below 65% where that restriction applies. Ownership or control changes and license transfers require prior OCM review in the circumstances described by OCM. Practical Underwriting Before accepting funds, obtain the investor’s complete criminal history from every jurisdiction, cannabis-license and regulatory history, civil-enforcement history, labor-compliance history, ownership in other cannabis applicants or licenses, intended economic rights, source of funds, and proposed management powers. Compare the exact statute of conviction—not merely the crime’s common name—to Rule 9810.1001, because federal and out-of-state offenses turn on matching elements. The investment documents, capitalization table, operating agreement, promissory note, security agreement, profit rights, veto rights, and side letters should all tell the same story. OCM requires continuing disclosure of true parties and invested-money sources, and materially false or omitted application information can itself support denial. This report addresses Minnesota adult-use cannabis-business licensing, not legal advice for a specific investor. Hemp-business applicants are treated differently because section 342.15’s background checks and disqualifications do not apply to hemp-business applicants or hemp workers

You request it from the Minnesota Office of Cannabis Management through your preliminary license record in Accela. Under the current law, your first extension—up to six months—must be granted upon request; a possible second extension of up to six months is discretionary and requires proof that you have made good-faith efforts to convert the preliminary approval into a full license. Current extension timeline Stage Time available Standard Preliminary approval 18 months Complete all final licensing requirements before expiration Initial extension Up to 6 months OCM must grant it when you request it Additional extension Up to 6 months OCM may grant it if you show good-faith progress toward licensure That provides up to 30 months total from preliminary approval if OCM approves the additional, good-faith extension. An expired preliminary approval cannot be converted into a cannabis business license, so submit the request well before the deadline. How to request it Check your preliminary-approval expiration date in your OCM/Accela record and identify the date that falls 60–90 days beforehand. Watch the email addresses associated with the application, including spam and junk folders. OCM has stated it will email preliminary-approval holders approximately 60 days before expiration with instructions for requesting an extension. The notice is expected to come from noreply@accela.com.mn Log in to Accela using the account tied to the preliminary approval. Look for an extension-related task, notification, or request option within the license/application record. Accela is OCM’s platform for submitting and updating information, paying fees, scheduling inspections, monitoring status, and printing license records. Submit the extension request before the preliminary approval expires. For your initial six-month extension, make a clear written request and retain a PDF or screenshot of the submission confirmation. If you may need a second extension, build the record now. The statute makes this one dependent on good-faith efforts, so prepare evidence rather than relying on a narrative alone. What to document Even if the first extension is mandatory upon request, a short, organized progress package can reduce questions and protect you if you later need the additional extension. Include: Accela application/license number, legal entity name, license type, and original preliminary-approval date. Facility address or your active site-selection status. Local zoning correspondence, zoning verification, conditional-use permit materials, or local registration documentation. Executed lease, purchase agreement, landlord letter, LOI, or explanation of a documented site contingency. Construction drawings, architect/engineer agreements, permit applications, bids, contractor schedules, and equipment orders. Final Plans of Record progress, including security plans, SOPs, floor plans, inventory controls, and operational-readiness documents. Evidence of completed or pending background checks and required ownership disclosures. Financing documentation showing capital raised, lender diligence, investor activity, or a buildout budget and timeline. A dated milestone schedule showing exactly what will be completed during the requested extension period. Documentation of delays outside your control, such as municipal review, permitting, utility upgrades, landlord construction, lender timelines, or OCM-requested revisions. Sample Request Language Subject: Request for Initial Extension of Preliminary License Approval — [Legal Entity Name] / [Accela Record Number] To the Minnesota Office of Cannabis Management: [Legal Entity Name], holder of preliminary license approval for a [license type], respectfully requests an initial extension of its preliminary license approval for up to six months under Minnesota Statutes, section 342.14.Our preliminary approval expires on [date]. We remain actively engaged in completing all requirements necessary to convert the preliminary approval into an operating cannabis business license. Current progress includes [brief list: site control/zoning, plan development, financing, permitting, construction, final-plan preparation, etc.]. During the extension period, we expect to complete the following milestones: [list the remaining steps and target dates]. Please confirm receipt and approval of this request through Accela or the contact information below. Sincerely, [Name] [Title] [Legal Entity Name] [Accela Record Number] [Email] | [Phone] Important distinction Do not confuse this with annual license renewal. An extension applies while you hold preliminary approval and are trying to obtain your initial operating license. Once the full license is issued, OCM requires annual renewal through Accela, with the renewal application generally made available 90 days before expiration.mn If you have not received OCM’s 60-day email and are within roughly 75 days of expiration, submit an inquiry through your Accela record or contact OCM promptly—do not wait for the expiration date.

Need to gain Social Equity Status? Minnesota Office of Cannabis Management now allows SEA approvals (typically takes 2-3 business days currently)? Visit Qualifications / Office of Cannabis Management. For the OCM programs, visit mn.gov/ocm/businesses/grants, and for DEED programs, visit mn.gov/deed. Office of Cannabis Management (OCM) Grant Programs - LINK CanGrow (OCM-SEA approved status) — Currently Open Primarily focused on farmers/cultivators, so it has limited direct relevance to other licenses such as Manufacturing/Wholesale/Transport/Delivery licenses. However, if you have any cultivation component or are working with farming partners, this may apply. Technical assistance grants: $10,000–$50,000 for training and education Farmer loan financing: $2,500–$50,000 per individual (up to $150,000 with matching funds) Current deadline: June 1, 2026 at 4:30pm CST. Applications go through OCM's online portal CanRenew (OCM-SEA approved status) — Next Round TBD (Mid to Late 2026) Provides community restoration grants in areas disproportionately impacted by cannabis prohibition. Important caveat: CanRenew funds cannot be used for cannabis business operations or revenue-generating activities — it funds community-oriented projects (economic development, youth programs, violence prevention, civil legal aid). FY2026 allocation: $10.9 million total Tier 1: $2,500–$10,000 for smaller/newer organizations Tier 2: $50,000–$2,000,000 for larger projects The FY2026 application window was Nov. 2025 – Jan. 12, 2026 (now closed); watch for the FY2027 cycle updates (mid to late 2026). Minnesota Department of Employment and Economic Development (DEED) Grant & Loan Programs - LINK CanNavigate (DEED) — Active, Service Providers Selected DEED partnered with community-based organizations to provide free technical assistance to cannabis entrepreneurs navigating OCM's regulatory structure. As an SEA, you can access services from a CanNavigate provider (rather than apply as a provider yourself) at no cost. Total program funding: $2 million Priority is given to SEAs and disproportionately impacted communities Contact DEED or OCM to be connected with a local CanNavigate partner organization CanStartUp (DEED) — Active Loan Program This is one of the most directly relevant programs for you. DEED awards grants to nonprofit lenders, who then make loans to new cannabis microbusinesses, with priority given to SEAs. Program funding: $6 million allocated Priority given to social equity applicants. Limitation: Technically written for microbusinesses — consult DEED to confirm eligibility for other license types Access through DEED-selected nonprofit lenders, not directly from DEED CanTrain (DEED) — Workforce Development Grants to organizations providing cannabis workforce training. Directly relevant if you need to hire and train staff. Grants up to $500,000 per organization Next deadline listed as December 2, 2026 You would work with a CanTrain-funded organization for workforce development DEED Veteran-Specific Programs Reservist and Veteran Business Loan Program - LINK Specifically designed for veterans starting businesses. Directly relevant to you as a veteran SEA. Interest-free loans of $5,000–$20,000 For veterans who were on active duty on or after September 11, 2001 Must have separated under honorable conditions after 181+ consecutive days of active duty Apply through DEED directly Emerging Entrepreneur Loan Program (ELP) - LINK One of the most flexible programs for veteran-owned businesses. Loans of $5,000–$150,000 for businesses at least 51% owned by a veteran (among other qualifying categories) Can fund startup costs, equipment, inventory, working capital, renovation, and site acquisition DEED provides funds through certified nonprofit lenders statewide Interest rates capped (not to exceed 4% over Wall Street prime) Available through lenders like Southern Minnesota Initiative Foundation, RAEDI, and others. What's Not Available to You SBA/USDA federal loans are unavailable for state-legal cannabis businesses due to federal prohibition — these apply only to hemp businesses with under 0.3% THC. Iron Range Resources (IRRRB) loans explicitly exclude transportation and retail cannabis operations from eligibility. Minnesota Department of Revenue does not offer grants for cannabis businesses; their cannabis-related programs focus on local government aid, which was actually repealed by the 2025 Legislature. Recommended Action Plan Grant Priority Program What to Do Immediate CanGrow Apply by June 1, 2026 if you have a farming/cultivation angle. Now CanNavigate Contact DEED to connect with a free CanNavigate service provider for regulatory guidance. Now Veteran Business Loan Apply through DEED for 0% interest startup loan up to $20,000. Now ELP (Emerging Entrepreneur Loan Program) Apply through a certified nonprofit lender for up to $150,000. Ongoing CanStartUp Work with a DEED-selected nonprofit lender for microbusiness loan access. FY2027 Late CanRenew Watch OCM for the next application cycle (community-focused projects only). Need help navigating the grant process? Reach out to us at info@carpfishcreative.com.

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