For both sides
Tier
Federal and state law current as of September 2026 — verify with counsel.
Key takeaways
- A license size class (plants, canopy, or revenue). Moving tiers is often a new application.
- 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.
A license size class (plants, canopy, or revenue). Moving tiers is often a new application. Federal and state law current as of September 2026 — verify with counsel. This is educational, not a guarantee of price, timing, approval, or financing.
Why Tier matters in a cannabis sale — how should you read this on Tier?
Tier is a closing-path word. If the CIM uses it loosely, Illinois counsel and Minnesota counsel will not mean the same thing. HedgeStone keeps the statutory meaning.
How Tier is used correctly — how should you read this on Tier?
On a live tier question, ask whether it changes approvability, cash, or both. Counsel confirms the citation. This page is educational.
How Tier is misused — what belongs on Tier?
Lenders and buyers sometimes ask for a right that tier cannot legally give. Name the document that actually carries the right.
| Use of Tier | Broker reading |
|---|---|
| Tier in a CIM | Must match the statute, not a slogan |
| Tier in an LOI | If it requires agency consent, say so |
| Tier in a model | Label ranges; do not hide 280E |
| Tier vs a neighbor word | Do not swap tier for a look-alike term from another state |
File example that turns on Tier — why does this change Tier?
Illustrative: counsel strikes tier from an LOI because the agency cannot honor the sentence. The parties rewrite. That is a successful close path.
Nearby words people confuse with Tier — what should you verify for Tier?
If someone says tier and means a different glossary entry, stop and pick the right slug. The glossary index exists so Tier stays precise.
Treat Tier as a state-license file with a federal tax and banking overlay. Schedule III medical relief is real for qualifying activity and irrelevant to an adult-use-only book. Hemp SKUs face CRS IN12620 on the 2026 hemp definition on 12 November 2026. Do not import a 2021 multiple onto that fact pattern.
Cited sources that govern Tier: 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. 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.
Related pages for Tier — what breaks Tier?
Read 280E next if that file is open on Tier. METRC is the companion page when Tier needs that angle. Keep glossary index in the working set for Tier. Read federal law next if that file is open on Tier. 280E is the companion page when Tier needs that angle. Keep deal structure in the working set for Tier. Read sell next if that file is open on Tier. buy is the companion page when Tier needs that angle.
Which public sources belong on this file?
Cite USCIS Policy Manual, U.S. Treasury, DEA drug scheduling, DEA diversion schedules. A forum post is not a substitute.
Frequently asked questions
What does Tier mean in a cannabis sale?
A license size class (plants, canopy, or revenue). Moving tiers is often a new application.
Is this legal advice?
No. Confirm the term against the statute and counsel.
Does the definition travel across states?
No. Tier in one statute is not automatically Tier in another.
Where does it show up in a deal?
Applications, LOIs, CIMs, and often the approval contingency.
Sources
- 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)
- Federal Register 2026-08176 (28 April 2026) — medical / FDA-approved marijuana to Schedule III — https://www.federalregister.gov/d/2026-08176
- 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
- USCIS Policy Manual — https://www.uscis.gov/policy-manual
- U.S. Treasury — https://home.treasury.gov/
- DEA drug scheduling — https://www.dea.gov/drug-information/drug-scheduling
- 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