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[lesgetrich]

Also, this is in slight contrast to what you and/or words said earlier, that mcig had obtained an establishment agent license. I believe the application is the same, but an establishment has to meet stricter reqirements, and i beleive they need to be applying as a cultivator, dispensary, grower, or lab tester.

Nevada offers four categories of MJ establishment licenses. A license for "Production of Edible Marijuana or Marijuana Infused Products" (Production License) is one category for companies that just want to buy MJ, process it into edibles or infused product like oils, and resell it.

Nevada MME FAQ

What kinds of medical marijuana facilities operate in Nevada?

There are four kinds of medical marijuana establishment definitions in Nevada:

Dispensary: As per NRS 453A.115, a business that is registered with the Division and acquires, possesses, delivers, transfers, transports, supplies, sells or dispenses marijuana or related supplies and educational materials to the holder of a valid registry identification card.

Cultivation Facility: As per NRS 453A.056, a business that is registered with the Division, and acquires, possesses, cultivates, delivers, transfers, transports, supplies or sells marijuana and related supplies to a medical marijuana dispensaries; facilities for the production of edible marijuana products or marijuana-infused products; or other cultivation facilities.

Production of Edible Marijuana or Marijuana Infused Products: As per NRS 453A.105, a business that is registered with the Division pursuant to NRS 453A.322, and acquires, possesses, manufactures, delivers, transfers, transports, supplies, or sells edible marijuana products or marijuana infused products to medical marijuana dispensaries.

Independent Testing Laboratory: As per NRS 453A.107, a business that is registered with the Division to test marijuana, edible marijuana products and marijuana- infused products. Such an independent testing laboratory must be able to determine accurately, with respect to marijuana, edible marijuana products and marijuana-infused products, the concentration therein of THC and cannabidiol, the presence and identification of molds and fungus, and the presence and concentration of fertilizers and other nutrients.

So you see, labor does involve transport and sale of MJ as these are part of the MME's responsibility. Agents licenses are offered to people and independent contractors who want to supply labor (which logically includes any services such as transporting and selling). This is a separate license with separate requirements than those of an MME.

How does the agent card application process work?

All agent card registration is done electronically through a web-based interface provided by the Division. The designee and the Division can access agent card information on the site. Only MME designees have login access to the system. The designees manage all agent card business for their establishment(s) on the secure agent card website with special access.

Words pointed out that mCig could legally sell MJ with either a Production or Agents license but I don't recall him saying that they had obtained an Production Establishment license. I certainly never made that claim. They may have applied for an establishment license or may intend to do so in the future but they can do everything they need to do with an Agents License.

The Agent's license is easier and cheaper to obtain and I'd say it's safe to assume that they've applied for and obtained one. It also may explain why they didn't start Rollies sales in June as expected if they had to wait 30 days to get a license. All production and sales employees would need to be fingerprinted and would each need to sign applications. It's easy to imagine how collecting this info from each employee and making sure the applications are correctly completed can take a few weeks. Keep in mind, employees can't even set foot inside the facility until they are properly licensed.

I'm not sure they can really claim to have a license even if one of the reps has a agent cetificate as i would think that woukd be filed under the individual if mcig doesn't have an establishment license. I admit i could be wrong on this, but i believe the idea is mj company is contracting with the individual in this case.

This is dead wrong.

What about independent contractors who provide MMEs with employees--do these third-party licensees need agent cards?

Not only do the employees of independent contractors who work at MMEs need cards, but the independent contractor him or herself must also have agent card(s), per AB 70, Section 31.

19) Do third-party licensees have to obtain MME agent cards for each licensed location?

Persons wishing to provide labor to more than one registered MME as an independent contractor may do so, but pursuant to the law, those persons do not make application directly to the DPBH. Instead, each registered MME must submit an application for each of its independent contractors. Therefore, an independent contractor may have MME agent cards for more than one registered MME.

As for your assertion...

There are also extensive courses an agent needs to pass before providing any services, so it's also not as easy as submitting an applucation for an agent certificate.

This training is supplied by the MME and is their responsibility. I would be willing to bet that mCig designed the course for its cultivator(s) as part of their consulting services.

What kinds of training are MMEs required to provide for the agents?

All agents will receive training on the proper use of security measures to prevent diversion, theft of loss of marijuana; procedures for responding to an emergency; and state and federal confidentiality rules related to the use of medical marijuana. Depending on the category of card being issued -- dispensary, cultivation, production or laboratory --- there are additional required training topics. NAC 453A.336