To understand the dilemma faced by state-approved cannabis businesses that are fortunate to generate millions of dollars in revenue, one might imagine the difficulty these businesses face operating without the financial services offered by federally regulated financial institutions. For instance, such businesses lack access to loans, credit cards, lines of credits, bank accounts and secured armored trucks for transporting cash receipts.

This situation is common for a "cannabis-related legitimate business or service provider" (CRLB) operating in New Jersey and other states, because the federal government classifies marijuana as a Schedule 1 controlled substance, creating a conflict in authority. Schedule 1 classification defines marijuana as having (i) a high potential for abuse, (ii) no currently accepted medical use, and (iii) no accepted safety standards for its use under medical supervision. Concerned about compliance requirements, federally regulated financial institutions have been reluctant to offer financial services to CRLBs.