We continue to represent myriad buyers and sellers of OLCC marijuana licenses. At any given time, we are running 10-12 of these transactions, and sometimes more, as we have for many years. Recently, there have been a few changes worth noting, particularly as to the OLCC protocols. I’ll touch briefly on other market dynamics, too.
The OLCC updates
a. Fast application assignments
Gone are the days of buyers and sellers waiting months to hear from an OLCC investigator, following submission of a change-of-ownership application. The OLCC’s “processing dates” page reports that change-of-ownership applications are now being assigned and processed through September 3, 2025 submissions. That’s not accurate. For the past month or so, we’ve seen a series of applications assigned within a week or two of submissions. These are moving fast.
b. Completed applications required
OLCC licensing staff have begun to pre-screen submissions, and they are returning applications that lack required documents. The old practice of uploading placeholder documents will no longer be accepted. The idea here is to ensure organized applicants aren’t forced to wait in line behind their disorganized counterparts, causing a bottleneck. Going forward, incomplete applications will only be placed into the assignment queue once all missing documents are provided.
c. 60-day assignment period going away
In case you missed it, OLCC filed a Notice of Proposed Rulemaking on September 25, 2025. The chief purpose was to implement 2025 legislation, but some technical updates made their way in, as well. One of these is proposed rules is OAR 845-025-1135(2)(A)-(B) which provide that applicants:
“… must complete the application process within 60 calendar days of the Commission notifying the applicant that the application has been assigned” and that “if the applicant does not complete the application process within 60 calendar days, the application will be unassigned and place on hold.”
Getting booted into this kind of purgatory is a dangerous game. Most purchase agreements have drop-dead dates, escrow forfeiture provisions, and other adverse consequences for buyers in particular who fail to adequately move things forward. On the seller side, a booted application can be devastating where there are landlord issues, or where a seller has given over the keys under a management agreement—something people are still doing regularly, often against advice.
d. Limited inspectors
We’ve seen some delays recently regarding OLCC inspector availability. There probably aren’t enough of them. Several are also assigned to broad territories, making scheduling a challenge. Things tend to slow down over year-end holidays, too. With changes-in-ownership, final inspections are typically required on both the buyer and seller side, and parties need to be flexible here.
Other market dynamics
a. Buyer’s market
Many OLCC license and business sales are “fire sales” nowadays. Many sellers are failing businesses looking to salvage some value, under duress, and make a hasty exit. This gives buyers significant leverage, which should continue unabated despite OLCC improving its processes, and despite the ongoing moratorium on new license issuances. This market dynamic is the new normal, and has been for a while.
b. Brokers
Oregon cannabis transactions continue to be plagued by unscrupulous or incompetent cannabis brokers, with a few exceptions. Every week, buyers and sellers come to us with confusing LOIs, hazardous purchase agreements, wacky leases and other contracts drafted by brokers, some of whom also purport to serve as escrows, application advisors and general deal consiglieres. We’ve talked to these brokers and even filed some unauthorized practice of law complaints; but ultimately it’s up to buyers and sellers to use common sense here.
c. Buyer profiles
We are seeing a large number of Chinese buyers in the last year or so, following the eastern European wave of purchasers a few years back. Existing chain operators also continue to scoop up licenses here and there. There is very little multi-state operator (MSO) action at this point, or Canadian public company interest.
Stay tuned
I’ll touch on all of this again at the end of the year, in my annual Oregon “State of the State” post. Until then, take care and please give us a call if you need assistance liquidating, or acquiring, an Oregon cannabis license.
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