BRONX, N.Y., June 8, 2026. The Bronx Cannabis Hub, a project of The Bronx Defenders, today submitted comments to the New York State Office of Cannabis Management (OCM) on its review of the adult-use cannabis regulations.

The comments call for reform in five areas where the current rules fall hardest on small and equity-licensed dispensaries: credit terms that ignore the cash-only reality of licensed cannabis retail, a pricing framework that leaves small operators exposed to undercutting, storefront and staffing rules that drive up the cost of running a store, advertising limits that keep licensed shops from reaching customers, and enforcement too sporadic to address the unlicensed shops operating in New York City. The comments urge OCM to extend credit terms and add a cure period before a missed payment lands an operator on a public delinquency list, and to set a price floor and cap volume discounts before the kind of price compression that pushed small growers out of California reaches New York.

These comments grew out of a semester-long engagement between Hub members, dispensary owners and operators holding CAURD licenses, and two law school clinical programs: the Criminal Defense Clinic at Columbia Law School and the Entrepreneurial Law Clinic at Fordham University School of Law. During the Spring 2026 semester, Columbia students conducted in-person interviews at five dispensaries, observing operations firsthand, while Fordham students interviewed owners at three dispensaries and analyzed the provisions governing credit terms and pricing. The owners shaped that research into the comments now before OCM.

The Hub does not submit these comments to criticize the Office’s work, but to seize a rare opportunity to calibrate the rules to the market they govern. The Marijuana Regulation and Taxation Act charged OCM with building a regulated market that repairs prohibition’s harms by ensuring that the communities most targeted by enforcement become the primary beneficiaries of legalization. These recommendations aim to keep that promise, so the rules support the equity licensees the market was built for rather than working against them.

Since 2022, the Hub has guided 27 entrepreneurs through the Conditional Adult-Use Retail Dispensary (CAURD) licensing process and provided over $2 million in pro bono legal and business support. Its members now run 17 dispensaries that have generated more than $35 million in sales, $7 million in new state and local tax revenue, and more than 125 full-time jobs.

“We were promised a chance to build generational wealth, but the rules punish operators for a single slow week. Being forced onto COD terms only makes it harder to restock inventory, generate revenue, and recover. Retailers should be allowed to work directly with their vendors, or at a minimum payment terms should be extended to net 60, the way the rest of retail does,” said Hub Members Patricia Conner & Roland Conner, Smacked Village

“CAURD licensees have demonstrated remarkable grit and resilience throughout this program, and our students responded this year by becoming genuine advocates through serious listening, research, and engagement with the market. This submission reflects that work, and the determination of operators who have earned the chance to thrive,” said Katherine Hughes, Clinical Associate Professor of Law & Director of The Entrepreneurial Law Clinic, Fordham University School of Law

“Our students went to these dispensaries to listen. They learned where regulations created barriers or stymied MRTA’s reparative goals. The people running these businesses understand the regulations better than anyone and navigate them everyday. Helping turn that collaborative experience into recommendations the state can act on is exactly the work our law school clinic is proud to do,” said Amber Baylor, Clinical Professor of Law & Founding Director of The Criminal Defense Clinic, Columbia Law School

“The students met our licensees where they were, in their stores, and listened. They took what these owners live every day and translated it into specific, workable recommendations, ones that reflect the material interests of the systems-impacted New Yorkers the MRTA was written to serve. I’m grateful for their work,” said Damian Fagon, Director, The Bronx Cannabis Hub

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