Bulletin | Required Suitability Notifications  | January 13, 2025

To:          Licensees and Registered Agents
From:     Investigations and Enforcement Department
Date:      January 13, 2025
Subject: Required Suitability Notifications

This Bulletin applies to all Marijuana Establishments, Medical Marijuana Treatment Centers, and Independent Testing Laboratories (collectively, “Licensees”) and their Registered Agents.

Pursuant to 935 CMR 500.801(3) and 501.801(3), all Licensees, Persons or Entities Having Direct or Indirect Control, and Registered Agents are required to remain suitable at all times a License or registration remains in effect. Each individual and entity subject to the suitability tables are independently responsible for notifying the Cannabis Control Commission (Commission) of any charge or conviction of an offense that would result in a Presumptive Negative Suitability Determination or a Mandatory Disqualification within ten days of arrest or summons, and within ten days of the disposition of the merits of the underlying charge. See 935 CMR 500.801(3) and 501.801(3). Failure to make proper notification to the Commission may result in suspension, revocation, or other enforcement action as deemed appropriate. See id.

Individual or entities subject to an event that results in a Presumptive Negative Suitability Determination or Mandatory Disqualification must submit notification via email to Licensing@CCCMass.com. Please see the breakdown of applicable suitability tables below:

• Applicants, Licensees, and Persons Having Direct or Indirect Control
  • 935 CMR 500.801: Table A
  • 935 CMR 501.801: Table A
• Registered Agents of Marijuana Establishments or Medical Marijuana Treatment Centers
  • 935 CMR 500.802: Tables B-D
  • 935 CMR 501.802: Table B
• Registered Agents of Independent Testing Laboratories
  • 935 CMR 500.803: Table E
  • 935 CMR 501.803: Table C

Notification should include the following information: (1) the subject person or entity; (2) the related License and registration numbers; (3) the applicable precipitating issue; (4) a summary of the event; and (5) any underlying documentation regarding the event. Commission staff will review the information provided and may request additional information, as deemed necessary by the CIE or their delegee.

If you have questions, please contact the Commission at (774) 415-0200 or Licensing@CCCMass.com.