For both sides
Schedule I / III
Federal and state law current as of September 2026 — verify with counsel.
Key takeaways
- CSA classes. I: 280E and high federal exposure. III: medical order of 28 April 2026; ordinary deductions for that activity.
- Use the term the way the regulator uses it.
- Do not import another state’s definition.
- Ask counsel before the LOI uses the word as a promise.
Schedule I / III is the file this page underwrites. CSA classes. I: 280E and high federal exposure. III: medical order of 28 April 2026; ordinary deductions for that activity. Federal and state law current as of September 2026 — verify with counsel.
Why Schedule I / III matters in a cannabis sale — what belongs on Schedule I / III?
Owners lose months when Schedule I / III is treated as slang. The application, the LOI, and the agency packet have to use one definition.
How Schedule I / III is used correctly — how should you read this on Schedule I / III?
The correct use of Schedule I / III is the one that a Michigan reviewer would recognize. Do not import a Ohio habit unless the premises sit there.
How Schedule I / III is misused — what belongs on Schedule I / III?
The usual misuse is turning schedule i / iii into a premium without a citation. Buyers then treat it as optional. Neither side can close on that.
| Use of Schedule I / III | Broker reading |
|---|---|
| Schedule I / III in a CIM | Must match the statute, not a slogan |
| Schedule I / III in an LOI | If it requires agency consent, say so |
| Schedule I / III in a model | Label ranges; do not hide 280E |
| Schedule I / III vs a neighbor word | Do not swap schedule i / iii for a look-alike term from another state |
File example that turns on Schedule I / III — how should you read this on Schedule I / III?
Illustrative: a CIM inflates schedule i / iii into a premium. Diligence removes it. Price moves. See APA vs MIPA if the term changes who keeps the liability.
Nearby words people confuse with Schedule I / III — how should you read this on Schedule I / III?
If someone says schedule i / iii and means a different glossary entry, stop and pick the right slug. The glossary index exists so Schedule I / III stays precise.
Jason Taken will not price Schedule I / III 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.
Cited sources that govern Schedule I / III: 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.
Related pages for Schedule I / III — what breaks Schedule I / III?
Read federal law next if that file is open on Schedule I / III. 280E is the companion page when Schedule I / III needs that angle. Keep deal structure in the working set for Schedule I / III. Read sell next if that file is open on Schedule I / III. buy is the companion page when Schedule I / III needs that angle. Keep 280E in the working set for Schedule I / III. Read METRC next if that file is open on Schedule I / III. glossary index is the companion page when Schedule I / III needs that angle.
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.
Frequently asked questions
What does Schedule I / III mean in a cannabis sale?
CSA classes. I: 280E and high federal exposure. III: medical order of 28 April 2026; ordinary deductions for that activity.
Is this legal advice?
No. Confirm the term against the statute and counsel.
Does the definition travel across states?
No. Schedule I / III in one statute is not automatically Schedule I / III in another.
Where does it show up in a deal?
Applications, LOIs, CIMs, and often the approval contingency.
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)