For both sides
Assignment for benefit of creditors
Federal and state law current as of September 2026 — verify with counsel.
Key takeaways
- As of September 2026, medical marijuana is Schedule III; adult-use remains Schedule I (Federal Register 2026-08176 and pending hearing).
- 280E still hits adult-use SG&A; medical books may take ordinary deductions — apportion dual licenses.
- SBA loans are unavailable for plant-touching targets (SOP 50 10 8).
- Deals close on regulatory approval; control does not move early.
- Single-store commentary multiples of about 3x–6x EBITDA are trade ranges, not appraisals (2025–2026 commentary).
Assignment for benefit of creditors is a priority-of-claims problem. Tax liens and receivers do not care about last year’s CIM. This page is written for owners and buyers and for more than one license class. It is not legal or tax advice.
Jason Taken will not price Assignment for benefit of creditors on a rumor that “rescheduling is done.” Medical rescheduling is done for the activity the order covers. Adult-use is not. FinCEN FIN-2014-G001 and SBA SOP 50 10 8 did not disappear in April 2026. H.R.9471 is the House companion, also unenacted.
| Topic | Working rule (verify, September 2026) |
|---|---|
| Audience | owners and buyers |
| License lens | more than one license class |
| Contrast markets | New York / Virginia / California |
| SBA | Unavailable for plant-touching (SOP 50 10 8) |
| Hemp clock | P.L. 119-37 redefinition 12 November 2026 |
| Commentary multiple (not an appraisal) | 3x–33x normalized earnings |
What a commentary multiple is not on Assignment for benefit of creditors — how should you read this on Assignment for benefit of creditors?
Trade notes still cite about 6x–63x normalized earnings for a clean single store. Public MSO chatter near 4.16x EV/EBITDA for 2025 is not a value for Assignment for benefit of creditors.
Hemp overlay if Assignment for benefit of creditors touches SKUs — what should you verify for Assignment for benefit of creditors?
P.L. 119-37 and CRS IN12620 on the 2026 hemp definition reset the definition on 12 November 2026. If Assignment for benefit of creditors includes delta-8 or other intoxicating hemp, underwrite the post-rule catalog.
MSA risk around Assignment for benefit of creditors — why does this change Assignment for benefit of creditors?
A management agreement that moves control before approval is a license event. Assignment for benefit of creditors does not get a clever close by calling the buyer a consultant.
Diligence order for Assignment for benefit of creditors — what should you verify for Assignment for benefit of creditors?
Agree whether Assignment for benefit of creditors is a scarcity file or a cash-flow file, then pick the diligence order. The checklist stays in the working set.
Documents that actually move Assignment for benefit of creditors — what belongs on Assignment for benefit of creditors?
License, local authorization, lease consent, tax clearance, 6 months of seed-to-sale exports, violation history, and the ownership chart. Missing one of those is not a formatting issue.
Who should not attempt Assignment for benefit of creditors — what breaks Assignment for benefit of creditors?
A buyer who cannot pass background or residency. An owner inside a holding period. A non-citizen who has not spoken to immigration counsel. USCIS still treats marijuana conduct as a controlled-substance issue.
How HedgeStone treats Assignment for benefit of creditors — what breaks Assignment for benefit of creditors?
Jason Taken will say if Assignment for benefit of creditors is transferable before anyone writes a CIM. He is a business broker, not an attorney and not a licensed operator. No invented listings, no invented MSO names.
Successor liability sitting under Assignment for benefit of creditors — how should you read this on Assignment for benefit of creditors?
Cannabis tax debt does not vanish because someone chose an asset sale. Clearance certificates and holdbacks exist for Assignment for benefit of creditors. See tax holdbacks.
Banking after Assignment for benefit of creditors — how should you read this on Assignment for benefit of creditors?
FinCEN FIN-2014-G001 is still the SAR frame. A new owner who assumes the seller’s bank will keep the account is guessing. Model cash handling until the successor account is real.
When to walk away from Assignment for benefit of creditors — what should you verify for Assignment for benefit of creditors?
If the license is locked, the city will not host the buyer, the books cannot be rebuilt, or the hemp catalog dies in November 2026, the honest answer is stop. Assignment for benefit of creditors is not improved by optimism.
Partner and dispute uses of Assignment for benefit of creditors — what breaks Assignment for benefit of creditors?
Buyouts and shareholder fights still need a method, not a slogan. Label ranges. Do not pretend a liquor-store rule prices Assignment for benefit of creditors.
Inventory and biomass on Assignment for benefit of creditors — how should you read this on Assignment for benefit of creditors?
What is on the floor at close has to match the state system. Failed tests and unsold canopy are price, not atmosphere. Count it.
Real estate attached to Assignment for benefit of creditors — why does this change Assignment for benefit of creditors?
The building can be the deal or the trap. No cannabis-use clause means Assignment for benefit of creditors cannot operate after assignment. Sale-leasebacks are capital, not magic.
Social-equity paper inside Assignment for benefit of creditors — why does this change Assignment for benefit of creditors?
Eligible-transferee rules and holding periods are deal terms. Assignment for benefit of creditors that ignores them is a letter, not a close. See social-equity locks.
Cited sources that govern Assignment for benefit of creditors: SBA SOP 50 10 8 keeps plant-touching targets out of 7(a) and 504, including medical. SAFE Banking Act of 2026, S.4942 and H.R.9471 were introduced in 2026 and are not law. Hemp SKUs must be read against CRS IN12620 on the 2026 hemp definition and CRS IF13136; the redefinition date is 12 November 2026. Federal Register 2026-08176 is the April 2026 medical / FDA-approved marijuana Schedule III order.
What to bring to the intro call — how should you read this on Assignment for benefit of creditors?
Book twenty minutes with Jason Taken at HedgeStone Business Advisors. For Assignment for benefit of creditors, bring the license class, the state, the local authorization status, and whether a buyer or target is already in the room. There is no form on this site and no invented listing book. He is a business broker, not an attorney and not a licensed cannabis operator.
Related pages for Assignment for benefit of creditors — how should you read this on Assignment for benefit of creditors?
Read ABC assignments next if that file is open on Assignment for benefit of creditors. tax-lien priority is the companion page when Assignment for benefit of creditors needs that angle. Keep bankruptcy gap in the working set for Assignment for benefit of creditors. Read receivership next if that file is open on Assignment for benefit of creditors. bankruptcy gap is the companion page when Assignment for benefit of creditors needs that angle. Keep selling in distress in the working set for Assignment for benefit of creditors. Read buying distressed next if that file is open on Assignment for benefit of creditors. receivership sales is the companion page when Assignment for benefit of creditors needs that angle.
Summary on Assignment for benefit of creditors — how should you read this on Assignment for benefit of creditors?
Assignment for benefit of creditors turns on approval, after-tax cash, and the license class. Federal law current as of September 2026 is a schedule split, not a green light. Verify every rate, cap, and clock with counsel.
Which public sources belong on this file?
Read DEA diversion schedules, FDA cannabis / CBD page, IRS marijuana industry page, eCFR CSA schedules alongside the agency packet. A forum post is not a substitute.
How should you underwrite Assignment for benefit of creditors?
Assignment for benefit of creditors has to rebuild as a license-and-tax file. In Illinois, scarcity can dominate. In Minnesota, paper value can be near zero. Cited sources that govern Assignment for benefit of creditors: SBA SOP 50 10 8 keeps plant-touching targets out of 7(a) and 504, including medical. SAFE Banking Act of 2026, S.4942 and H.R.9471 were introduced in 2026 and are not law. Hemp SKUs must be read against CRS IN12620 on the 2026 hemp definition and CRS IF13136; the redefinition date is 12 November 2026. Federal Register 2026-08176 is the April 2026 medical / FDA-approved marijuana Schedule III order.
| Check | Illinois | Minnesota |
|---|---|---|
| Transfer / host | Verify agency | Verify city |
| Tax / 280E mix | Medical slice | Adult-use slice |
What does a 280E-literate CPA ask?
Assignment for benefit of creditors has to hold back as a license-and-tax file. In California, scarcity can dominate. In Pennsylvania, paper value can be near zero. Cited sources that govern Assignment for benefit of creditors: SAFE Banking Act of 2026, S.4942 and H.R.9471 were introduced in 2026 and are not law. Hemp SKUs must be read against CRS IN12620 on the 2026 hemp definition and CRS IF13136; the redefinition date is 12 November 2026. Federal Register 2026-08176 is the April 2026 medical / FDA-approved marijuana Schedule III order. IRC §280E still disallows ordinary deductions on Schedule I trafficking, which is why adult-use books stay in 280E.
| Check | California | Pennsylvania |
|---|---|---|
| Transfer / host | Verify agency | Verify city |
| Tax / 280E mix | Medical slice | Adult-use slice |
How should approval be sequenced?
Assignment for benefit of creditors has to document as a license-and-tax file. In Colorado, scarcity can dominate. In Connecticut, paper value can be near zero. Cited sources that govern Assignment for benefit of creditors: Hemp SKUs must be read against CRS IN12620 on the 2026 hemp definition and CRS IF13136; the redefinition date is 12 November 2026. Federal Register 2026-08176 is the April 2026 medical / FDA-approved marijuana Schedule III order. IRC §280E still disallows ordinary deductions on Schedule I trafficking, which is why adult-use books stay in 280E. FinCEN FIN-2014-G001 remains the SAR frame banks actually use.
| Check | Colorado | Connecticut |
|---|---|---|
| Transfer / host | Verify agency | Verify city |
| Tax / 280E mix | Medical slice | Adult-use slice |
Where does the file break in Michigan versus Ohio?
Assignment for benefit of creditors has to age as a license-and-tax file. In Michigan, scarcity can dominate. In Ohio, paper value can be near zero. Cited sources that govern Assignment for benefit of creditors: Federal Register 2026-08176 is the April 2026 medical / FDA-approved marijuana Schedule III order. IRC §280E still disallows ordinary deductions on Schedule I trafficking, which is why adult-use books stay in 280E. FinCEN FIN-2014-G001 remains the SAR frame banks actually use. SBA SOP 50 10 8 keeps plant-touching targets out of 7(a) and 504, including medical.
| Check | Michigan | Ohio |
|---|---|---|
| Transfer / host | Verify agency | Verify city |
| Tax / 280E mix | Medical slice | Adult-use slice |
Frequently asked questions
How long can a license transfer take?
Published clocks vary by state and completeness. Treat 60–180+ days after a complete packet as a broker range unless the agency publishes a deadline. Arizona and Oregon do not share a clock on Assignment for benefit of creditors.
Can control move before approval?
Not if you want to keep the license. Stage closing and keep any MSA inside what the statute allows. Assignment for benefit of creditors is still an agency event.
Will SBA finance a plant-touching purchase?
No. [SBA SOP 50 10 8](https://www.sba.gov/document/sop-50-10-lender-development-company-loan-programs) treats plant-touching marijuana businesses as ineligible for 7(a) and 504, including medical. Assignment for benefit of creditors needs another stack.
What does HedgeStone actually do here?
Eligibility pre-screen, confidential match, METRC-aware pricing, and an approval-contingent process. Not a guaranteed price or a guaranteed yes. That is the job on Assignment for benefit of creditors.
Is this legal or tax advice?
No. Educational only. Use cannabis-specialized counsel and a 280E-literate CPA. Jason Taken is a business broker, not an attorney and not a licensed operator.
Which records actually prove the story?
Track-and-trace, tax filings, the lease cannabis-use clause, and a cap table that matches the application. A vanity P&L is a brochure when you are underwriting Assignment for benefit of creditors.
Sources
- FinCEN FIN-2014-G001 — BSA expectations for marijuana-related businesses — https://www.fincen.gov/resources/statutes-regulations/guidance/bsa-expectations-regarding-marijuana-related-businesses
- SBA SOP 50 10 8 (effective 1 June 2025) — marijuana ineligibility — https://www.sba.gov/document/sop-50-10-lender-development-company-loan-programs
- Congress.gov S.4942 — SAFE Banking Act of 2026 (introduced, not enacted) — https://www.congress.gov/bill/119th-congress/senate-bill/4942
- Congress.gov H.R.9471 — companion SAFE Banking bill — https://www.congress.gov/bill/119th-congress/house-bill/9471
- CRS IF13136 / IN12620 — hemp definition change effective 12 November 2026 (P.L. 119-37) — https://www.congress.gov/crs-product/IN12620
- DEA diversion schedules — https://www.deadiversion.usdoj.gov/schedules/
- FDA cannabis and CBD page — https://www.fda.gov/news-events/public-health-focus/fda-regulation-cannabis-and-cannabis-derived-products-including-cannabidiol-cbd
- IRS marijuana industry — https://www.irs.gov/businesses/small-businesses-self-employed/marijuana-industry
- Federal Register 2026-08176 (28 April 2026) — medical / FDA-approved marijuana to Schedule III — https://www.federalregister.gov/d/2026-08176
- IRC §280E — https://www.law.cornell.edu/uscode/text/26/280E
- Viridian Capital public commentary — Tier 1 U.S. MSO EV/EBITDA ~4.16x (2025 consensus)