If you are an FI and you are looking to develop, implement, and mature a CRB portfolio, strongly consider assistance from consultants who are experts at operational compliance. As you execute on the eight directives in the Cole memo, consider that 7 of the 8 are strictly operational in nature, while only 1 is financial. I have pasted the Cole memo directive points below. Number 2 is financial. This underscores the importance of the due diligence side of your solution.

We have your solution. It is not difficult. Simply use the right approach.

•Preventing the distribution of marijuana to minors;
•Preventing revenue from the sale of marijuana from going to criminal enterprises, gangs and cartels;
•Preventing the diversion of marijuana from states where it is legal under state law in some form to other states;
•Preventing state-authorized marijuana activity from being used as a cover or pretext for the trafficking of other illegal drugs or other illegal activity;
•Preventing violence and the use of firearms in the cultivation and distribution of marijuana;
•Preventing drugged driving and the exacerbation of other adverse public health consequences associated with marijuana use;
•Preventing the growing of marijuana on public lands and the attendant public safety and environmental dangers posed by marijuana production on public lands; and
•Preventing marijuana possession or use on federal property.