At long last, the Washington State Liquor and Cannabis Board (“LCB”) has finished revising its “True Party of Interest” rule (TPI). This process started way back in August of 2018 and after many revisions and multiple legislative changes. The LCB approved the new rule on September 2, 2020 and they will go into effect on October 3, 2020.
I wrote about the draft rules in detail here and if you are unfamiliar with TPIs generally, I recommend reading that post first as it outlines the changes have made it into this final version of the TPI rule. This post will focus instead on my main takeaways from the new rule.
Who is a TPI?
The new TPI rule does not change the basic premise that any individual who owns a marijuana business is considered a TPI. The new TPI rule states that the following individuals will be considered a TPI with regards to the corresponding entity:
Entity True Party(ies) of Interest Sole proprietor Sole proprietor General partnership All partners Limited partnership, limited liability partnership, or limited liability limited partnership -All general partners
-All limited partners
Limited liability company (LLC) -All LLC members
-All LLC managers