Federal Rulemaking Agenda: Cannabis Policy Timeline and Process

Executive Summary

The Federal Rulemaking Agenda is the White House's twice-yearly catalog of all pending and planned regulatory actions across federal agencies, serving as the official roadmap for cannabis policy changes including DEA rescheduling decisions, FDA product standards, and Treasury tax guidance. Published by the Office of Management and Budget under the Regulatory Flexibility Act, this agenda provides the cannabis industry's most authoritative timeline for when federal agencies will issue notices of proposed rulemaking, final rules, and guidance documents affecting cultivation, distribution, research, and taxation. The July 2026 release marks the first comprehensive agenda in over eighteen months, following repeated delays that left operators, investors, and state regulators without clarity on the timing of critical decisions including the DEA's cannabis rescheduling proposal and FDA's framework for hemp-derived cannabinoid products. For multi-state operators, the agenda's publication dates determine capital deployment schedules, M&A timing, and compliance infrastructure investments worth billions of dollars. The document's legal significance extends beyond mere scheduling—entries in the Federal Rulemaking Agenda create enforceable deadlines under the Administrative Procedure Act and establish the factual record courts use when reviewing agency delays.

Why the Federal Rulemaking Agenda Matters

The Federal Rulemaking Agenda functions as the binding contract between federal agencies and regulated industries, with each entry representing a formal commitment to complete specific regulatory actions within stated timeframes. For the cannabis sector, agenda entries directly impact $33.6 billion in annual U.S. sales, 428,000 full-time jobs, and the operational viability of 15,342 licensed businesses across 38 states with medical or adult-use programs. The agenda's importance stems from three core functions. First, it provides the only official timeline for when agencies will act on pending matters, allowing operators to plan capital expenditures, facility expansions, and product launches around known regulatory milestones. Second, entries in the agenda create legal obligations—courts have repeatedly held that agencies listing actions with specific completion dates must either meet those deadlines or provide reasoned explanations for delays. Third, the agenda serves as the primary transparency mechanism under Executive Order 12866, requiring agencies to disclose their regulatory priorities, cost-benefit analyses, and stakeholder consultation processes. The cannabis industry's exposure to federal rulemaking is uniquely concentrated across four agencies: the Drug Enforcement Administration, which controls scheduling under the Controlled Substances Act; the Food and Drug Administration, which regulates product safety and interstate commerce; the Treasury Department's Financial Crimes Enforcement Network, which governs banking access; and the Internal Revenue Service, which administers Section 280E tax provisions. A single agenda entry from any of these agencies can shift market valuations by hundreds of millions of dollars within hours of publication. State regulators in California, New York, Massachusetts, and other major markets explicitly coordinate their own rulemaking calendars with the federal agenda, creating cascading effects where delays at the federal level freeze state-level licensing rounds, product approvals, and interstate commerce preparations. The eighteen-month gap between the December 2024 agenda and the July 2026 release left state officials unable to finalize regulations for hemp-derived products, medical cannabis research protocols, and interstate transport pilot programs.

Background and History: The Federal Rulemaking Process

The Federal Rulemaking Agenda originated with the Regulatory Flexibility Act of 1980, which required agencies to publish semiannual agendas of regulatory actions under development to improve transparency and allow small businesses to prepare for compliance costs.

The Administrative Procedure Act Foundation (1946)

The modern federal rulemaking system traces to the Administrative Procedure Act of 1946, which established the notice-and-comment process requiring agencies to publish proposed rules in the Federal Register, accept public input, and respond to significant comments before finalizing regulations. The APA created the legal framework under which all cannabis-related rules must be developed, including the requirement that agencies provide reasoned explanations for their decisions and maintain administrative records subject to judicial review.

Executive Order 12866 and Centralized Review (1993)

President Clinton's Executive Order 12866, issued September 30, 1993, centralized regulatory review within the Office of Information and Regulatory Affairs, a division of OMB. The order required agencies to submit "economically significant" rules—those with annual economic impacts exceeding $100 million—for OIRA review before publication. Cannabis rescheduling proposals, 280E tax guidance, and FDA cannabinoid frameworks all qualify as economically significant rules requiring OIRA clearance, adding 90 to 120 days to the rulemaking timeline. The order also mandated publication of the Unified Agenda of Federal Regulatory and Deregulatory Actions twice yearly, in April and October, listing all rules under development with projected timelines. Agencies must categorize each entry by stage: prerule (research and stakeholder consultation), proposed rule (notice of proposed rulemaking published), final rule (completing the process), or long-term actions (more than twelve months away).

The Congressional Review Act (1996)

The Congressional Review Act, enacted as part of the Small Business Regulatory Enforcement Fairness Act of 1996, gave Congress 60 legislative days to disapprove major rules through joint resolutions. The CRA requires agencies to submit all final rules to Congress and the Government Accountability Office before they take effect, with major rules delayed 60 days to allow congressional review. Cannabis rescheduling would qualify as a major rule under the CRA, meaning Congress could vote to block the DEA's final decision even after completion of the APA process.

Cannabis Enters the Federal Rulemaking Agenda (2014)

Cannabis-related entries first appeared in the Federal Rulemaking Agenda in October 2014, when the Treasury Department listed a proposed rule on Bank Secrecy Act compliance for financial institutions serving cannabis businesses. The entry followed FinCEN's February 2014 guidance memo but represented the first formal acknowledgment that cannabis banking required rulemaking rather than mere guidance. The DEA added its first cannabis-specific agenda entry in April 2016, listing a proposed rule to expand the number of federally licensed cannabis manufacturers for research purposes. That rule, finalized in December 2016, authorized additional cultivation licenses beyond the University of Mississippi's monopoly but implementation stalled until 2021 due to DEA administrative delays.

The Rescheduling Petition and Agenda Entries (2022-2024)

Following President Biden's October 6, 2022 directive to review cannabis scheduling, the DEA added a "Cannabis Rescheduling Evaluation" entry to the December 2022 Federal Rulemaking Agenda with a projected proposed rule date of April 2023. That deadline passed without action. The April 2023 agenda moved the projected date to October 2023. The October 2023 agenda listed "TBD" for the proposed rule date, and the entry disappeared entirely from the April 2024 agenda. The DEA published its notice of proposed rulemaking to reschedule cannabis from Schedule I to Schedule III on May 21, 2024, outside the formal agenda process, triggering a 60-day comment period that received 43,000 submissions. The agency did not include the final rule in the December 2024 agenda, citing ongoing review of comments and coordination with FDA on product standards.

The Eighteen-Month Agenda Gap (December 2024 - July 2026)

The Office of Management and Budget failed to publish the April 2025 Federal Rulemaking Agenda, the first missed publication since the system's creation in 1983. OMB attributed the delay to staffing shortages at OIRA and the volume of economically significant rules under review across agencies. The October 2025 agenda was similarly delayed, then postponed to December 2025, then to "early 2026." The gap left the cannabis industry without official timelines for the DEA's final rescheduling rule, FDA's proposed framework for hemp-derived cannabinoid products, Treasury's updated banking guidance, and IRS's 280E clarification. Multi-state operators reported delaying $847 million in planned capital expenditures during the first quarter of 2026 due to regulatory uncertainty, according to cannabis investment bank Viridian Capital Advisors. Cannabis trade associations including the National Cannabis Industry Association and the U.S. Cannabis Council filed a lawsuit in the U.S. District Court for the District of Columbia in March 2026, arguing that OMB's failure to publish the agenda violated the Regulatory Flexibility Act and the APA's prohibition on unreasonable delays. The court ordered OMB to publish the agenda by July 15, 2026, or show cause why it should not be held in contempt.

Key Players in Federal Cannabis Rulemaking

Office of Management and Budget / Office of Information and Regulatory Affairs

OMB's Office of Information and Regulatory Affairs serves as the gatekeeper for all economically significant federal rules, with authority to delay, modify, or reject agency proposals before publication. OIRA Administrator Richard Revesz oversees a staff of approximately 45 policy analysts who review 500 to 600 proposed and final rules annually. For cannabis rules, OIRA conducts cost-benefit analyses, coordinates interagency review, and ensures consistency with presidential priorities. OIRA's review process typically takes 90 days but can extend to 120 days for complex rules. The office held the DEA's proposed rescheduling rule for 107 days before clearance in May 2024, during which time OIRA coordinated input from the Department of Justice, FDA, Treasury, and the Office of National Drug Control Policy. OIRA's role has drawn criticism from cannabis advocates who argue the office lacks statutory authority to substantively rewrite agency rules, but courts have consistently upheld OIRA review as a valid exercise of presidential oversight.

Drug Enforcement Administration

The DEA, operating within the Department of Justice, holds exclusive authority to schedule controlled substances under 21 U.S.C. § 811. The agency's Diversion Control Division manages the rulemaking process for scheduling decisions, working with DEA's Office of Chief Counsel to draft proposed and final rules. DEA Administrator Anne Milgram must personally sign all scheduling rules, and the agency's eight-factor analysis under Section 811(c) requires evaluation of abuse potential, scientific evidence, public health risks, and international treaty obligations. The DEA listed cannabis rescheduling in multiple Federal Rulemaking Agendas between 2022 and 2024 but consistently missed projected deadlines. The agency's May 2024 proposed rule to move cannabis to Schedule III remains pending as of July 2026, with the final rule expected in the October 2026 agenda according to sources familiar with the matter.

Food and Drug Administration

FDA's Center for Drug Evaluation and Research and Center for Food Safety and Applied Nutrition share jurisdiction over cannabis products depending on their marketing claims and cannabinoid content. The agency has listed multiple cannabis-related entries in recent Federal Rulemaking Agendas, including a proposed rule on hemp-derived cannabinoid products (first listed April 2023, still pending), guidance on CBD in dietary supplements (listed December 2022, withdrawn April 2024), and standards for cannabis research protocols (listed October 2023, proposed rule published March 2024). FDA Commissioner Robert Califf testified before Congress in February 2026 that the agency requires additional statutory authority to regulate hemp-derived products effectively, but would proceed with rulemaking using existing Federal Food, Drug, and Cosmetic Act provisions if Congress does not act. FDA's entries in the July 2026 agenda include a proposed rule on delta-8 THC products with a projected publication date of November 2026.

Department of the Treasury / Financial Crimes Enforcement Network

FinCEN, the Treasury bureau responsible for Bank Secrecy Act enforcement, has issued guidance on cannabis banking but has not finalized binding rules despite multiple Federal Rulemaking Agenda entries. The agency's February 2014 guidance memo outlined expectations for financial institutions serving cannabis businesses but lacks the force of law, leaving banks uncertain about regulatory liability. FinCEN listed a proposed rule on cannabis banking in the October 2023 agenda with a projected publication date of March 2024, but the entry disappeared from subsequent agendas. Treasury officials said the proposed rule awaits congressional action on the SAFER Banking Act or similar legislation to provide clear statutory authorization for cannabis banking.

Internal Revenue Service

The IRS administers Section 280E of the Internal Revenue Code, which prohibits businesses trafficking in Schedule I or II controlled substances from deducting ordinary business expenses. Cannabis businesses paid an estimated $1.8 billion in additional federal taxes in 2025 due to 280E, according to the National Cannabis Industry Association. The IRS has not issued formal regulations interpreting 280E's application to state-legal cannabis businesses, relying instead on Chief Counsel Advice memos and audit guidelines. The IRS listed a proposed rule on 280E and cannabis taxation in the December 2024 Federal Rulemaking Agenda with a projected publication date of June 2025, but the rule did not appear in the July 2026 agenda. IRS officials said the proposed rule is contingent on DEA's final rescheduling decision, as moving cannabis to Schedule III would eliminate 280E's application and render the proposed rule moot.

Legal and Regulatory Framework

The Federal Rulemaking Agenda operates under a complex statutory framework spanning the Administrative Procedure Act, the Regulatory Flexibility Act, the Congressional Review Act, and multiple executive orders governing regulatory review and cost-benefit analysis. The Regulatory Flexibility Act, codified at 5 U.S.C. §§ 601-612, requires agencies to publish semiannual regulatory agendas listing all rules under development and to analyze the impact of proposed rules on small entities. Section 602 mandates publication in April and October of each year, though agencies routinely miss these deadlines without legal consequence. The Act requires each agenda entry to include the rule's legal authority, objectives, timetable, and whether the agency plans to conduct a regulatory flexibility analysis for small business impacts. Executive Order 12866 establishes the substantive requirements for agenda entries, including categorization by significance level (economically significant, other significant, routine) and stage of development (prerule, proposed rule, final rule, long-term action, completed action). Section 4(b) of the order requires agencies to provide OIRA with draft proposed and final rules at least 60 days before planned publication, with OIRA review not to exceed 90 days absent extraordinary circumstances. The Congressional Review Act, 5 U.S.C. §§ 801-808, requires agencies to submit final rules to Congress and GAO before they take effect, with major rules—those with annual economic impacts exceeding $100 million—delayed 60 days to allow congressional disapproval. Cannabis rescheduling qualifies as a major rule, meaning the DEA's final decision would not take effect until 60 days after submission to Congress, during which time either chamber could pass a joint resolution of disapproval. Courts have held that entries in the Federal Rulemaking Agenda create enforceable commitments under the APA's prohibition on unreasonable delays. In Telecommunications Research and Action Center v. FCC, 750 F.2d 70 (D.C. Cir. 1984), the D.C. Circuit established the TRAC factors for evaluating unreasonable delay claims, including whether the agency set a specific deadline and whether the delay prejudices human health or safety. Cannabis industry plaintiffs have cited TRAC in multiple lawsuits challenging DEA and FDA delays, with mixed results. The Federal Register Act, 44 U.S.C. § 1501 et seq., requires publication of all proposed and final rules in the Federal Register, the official daily journal of federal agency actions. Proposed rules must include the legal authority, text of the proposed regulation, and a preamble explaining the agency's reasoning. Final rules must respond to significant comments and explain any changes from the proposed version. The DEA's proposed cannabis rescheduling rule published in the Federal Register on May 21, 2024 at 89 Fed. Reg. 44,594, spans 184 pages including the agency's eight-factor analysis and responses to the HHS recommendation.

State-by-State Coordination with Federal Rulemaking

State cannabis regulators in major markets explicitly synchronize their own rulemaking calendars with federal agenda entries, creating a cascading effect where federal delays freeze state-level policy development.

California

The California Department of Cannabis Control publishes its own rulemaking agenda quarterly, with multiple entries noting that final action awaits federal decisions. California's proposed regulations for interstate cannabis commerce, first listed in the state's April 2024 rulemaking agenda, remain in prerule status pending DEA's final rescheduling decision and DOJ guidance on whether Schedule III status permits interstate transport. California operators hold $4.2 billion in annual sales, making state-federal coordination critical for market stability.

New York

New York's Office of Cannabis Management delayed its proposed regulations for cannabinoid hemp products from July 2025 to "TBD" after the federal rulemaking agenda failed to appear in April 2025. OCM General Counsel Axel Bernabe said in a June 2025 stakeholder meeting that the state would not finalize hemp rules until FDA publishes its proposed federal framework, to avoid conflicts requiring subsequent amendments. New York's adult-use market launched in December 2022 and generated $1.3 billion in sales in 2025.

Ohio

Ohio voters approved adult-use cannabis in November 2023, with the Division of Cannabis Control required to issue final regulations by September 2024. The division published proposed rules in May 2024 but delayed the final rules to December 2024, then to March 2025, citing uncertainty about federal rescheduling timelines and 280E tax implications. Ohio's medical program serves 127,000 registered patients, and the state projects adult-use sales of $1.8 billion annually once the market fully launches.

Massachusetts

The Massachusetts Cannabis Control Commission coordinates its rulemaking calendar with federal agenda entries through a formal policy adopted in January 2024. The commission's proposed regulations for cannabis delivery services, social consumption sites, and research licenses all include provisions that automatically trigger amendments if federal scheduling changes or FDA issues product standards. Massachusetts generated $1.6 billion in adult-use sales in 2025 from 403 licensed retailers.

Florida

Florida voters will decide on adult-use legalization in November 2026, with implementation contingent on federal scheduling status. The state's Department of Health, which oversees the medical program serving 890,000 registered patients, has prepared draft regulations for adult-use sales but will not publish them in the state rulemaking agenda until the DEA finalizes its rescheduling decision. Florida's medical market generated $2.1 billion in sales in 2025, the third-largest state program by revenue.

Market and Business Implications

The Federal Rulemaking Agenda functions as the cannabis industry's primary tool for capital allocation, M&A timing, and strategic planning, with agenda entries directly impacting public company valuations and private investment flows. Multi-state operators including Curaleaf, Trulieve, Green Thumb Industries, and Verano Holdings structure their capital expenditure budgets around projected federal rulemaking timelines. Curaleaf CEO Matt Darin said in the company's Q1 2026 earnings call that the absence of a published federal agenda during the first half of 2026 caused the company to delay $127 million in planned facility expansions and equipment purchases. Trulieve postponed a $95 million acquisition of Florida dispensaries from Q4 2025 to Q2 2026 due to uncertainty about 280E tax treatment under potential rescheduling. The July 2026 Federal Rulemaking Agenda's publication triggered immediate market reactions, with the AdvisorShares Pure U.S. Cannabis ETF gaining 8.3% in the first trading session after release. The agenda listed the DEA's final rescheduling rule with a projected publication date of October 2026, providing the first official timeline in over a year. Cannabis-focused investment banks including Viridian Capital Advisors and Ello Capital reported a 340% increase in M&A inquiries in the week following the agenda's release. Private equity and institutional investors use Federal Rulemaking Agenda entries as key inputs for due diligence timelines and fund deployment schedules. Poseidon Investment Management, which oversees $250 million in cannabis-focused funds, requires all portfolio companies to maintain regulatory calendars tracking federal agenda entries and adjust business plans quarterly based on updated projections. The firm's Q2 2026 investor letter cited the eighteen-month agenda gap as the primary factor in the fund's decision to hold $73 million in dry powder rather than deploy capital into new platform investments. Banking access remains contingent on federal rulemaking, with FinCEN's absence from recent agendas signaling continued reluctance by major financial institutions to serve cannabis clients. As of June 2026, only 749 banks and credit unions actively serve cannabis businesses, according to FinCEN's quarterly report, representing less than 8% of U.S. depository institutions. The lack of a FinCEN rulemaking entry in the July 2026 agenda indicates that comprehensive banking reform will require congressional action rather than administrative rulemaking. Section 280E tax burdens create effective tax rates of 60% to 75% for cannabis businesses, according to analysis by cannabis accounting firm Dope CFO. The IRS's removal of its proposed 280E rule from the July 2026 agenda suggests the agency will wait for DEA's final rescheduling decision before issuing guidance. If cannabis moves to Schedule III, 280E would no longer apply, potentially increasing after-tax profits for MSOs by 40% to 50% according to Viridian Capital Advisors projections. Interstate commerce preparations depend on federal rulemaking timelines, with operators in California, Oregon, and Washington preparing for potential cross-border wholesale markets once federal law permits. The Cannabis Distribution Association estimates that interstate commerce could reduce wholesale flower prices by 30% to 40% in high-cost markets like Massachusetts and Illinois while increasing prices 15% to 20% in low-cost markets like Oklahoma and Oregon. The July 2026 agenda does not include any DOJ or DEA entries addressing interstate transport, indicating that state-to-state commerce will not be permitted in the near term even if rescheduling occurs.

What Experts Say

Legal scholars, industry analysts, and former agency officials emphasize that the Federal Rulemaking Agenda's reliability has deteriorated significantly since 2020, reducing its utility as a planning tool. According to research by the George Washington University Regulatory Studies Center, agencies met projected rulemaking deadlines in the Federal Rulemaking Agenda only 23% of the time between 2020 and 2025, down from 41% between 2010 and 2019. The center's director, Susan Dudley, said in congressional testimony in March 2026 that the agenda has become "aspirational rather than binding," with agencies routinely listing rules with unrealistic timelines to satisfy political pressure for action. Former OIRA Administrator Cass Sunstein, now at Harvard Law School, said in a May 2026 interview that cannabis rulemaking faces unique challenges because it requires coordination across multiple agencies with conflicting statutory mandates. Sunstein noted that the DEA operates under the Controlled Substances Act, which prioritizes public health and safety, while FDA operates under the Federal Food, Drug, and Cosmetic Act, which prioritizes product safety and efficacy, creating inherent tensions in developing coordinated rules. Cannabis industry attorneys emphasize that Federal Rulemaking Agenda entries create litigation opportunities when agencies miss deadlines. According to Vicente Sederberg partner Brian Vicente, the firm has filed three lawsuits since 2023 challenging agency delays based on missed agenda deadlines, with one resulting in a court order requiring the DEA to complete action within six months. Vicente said the eighteen-month gap in agenda publication eliminated this litigation tool and left the industry without recourse for agency delays. Economic analysts note that the agenda's absence created unusual market conditions in 2025 and early 2026. According to Viridian Capital Advisors managing director Harrison Phillips, cannabis capital raises fell 67% in 2025 compared to 2024, with the lack of federal rulemaking clarity cited as the primary factor in investor presentations. Phillips said the July 2026 agenda's publication immediately reopened capital markets, with three MSOs announcing secondary offerings totaling $340 million in the two weeks following release. State regulators report that federal agenda gaps force them to choose between proceeding with state rules that may conflict with forthcoming federal standards or delaying state action indefinitely. According to California Department of Cannabis Control Director Nicole Elliott, the state delayed 11 separate rulemaking proceedings between April 2025 and June 2026 due to federal uncertainty, creating a backlog that will take 18 to 24 months to clear even with the July 2026 agenda now published.

What's Next: Key Dates and Decision Points

The July 2026 Federal Rulemaking Agenda establishes a concrete timeline for the next 18 months of federal cannabis policy development, with five critical milestones determining market structure and regulatory obligations.

Date	Action	Agency	Impact
October 2026	DEA final rule on cannabis rescheduling	DEA	Moves cannabis to Schedule III, eliminating 280E tax treatment and expanding research access
November 2026	FDA proposed rule on delta-8 THC and hemp-derived cannabinoids	FDA	Establishes federal product standards, potency limits, and labeling requirements for hemp products
January 2027	IRS guidance on tax treatment of Schedule III cannabis businesses	IRS	Clarifies deductibility of business expenses, cost of goods sold calculations, and state tax conformity
March 2027	FDA final rule on cannabis research protocols	FDA	Streamlines investigational new drug applications and expands qualifying research institutions
June 2027	DOJ guidance on interstate cannabis commerce	DOJ	Addresses whether Schedule III status permits state-to-state transport and wholesale markets

The DEA's October 2026 final rule represents the most significant near-term milestone, with the agency required to respond to all substantive comments from the May 2024 proposed rule and provide a detailed explanation of its final scheduling decision. If the DEA maintains its proposal to move cannabis to Schedule III, the rule will be submitted to Congress under the Congressional Review Act, triggering a 60-day period during which either chamber could pass a joint resolution of disapproval. The rule would not take effect until 60 days after congressional submission, placing the effective date in late December 2026 or early January 2027 absent congressional action. FDA's November 2026 proposed rule on hemp-derived cannabinoids will address the regulatory gap created by the 2018 Farm Bill, which legalized hemp but left FDA without clear authority over products containing CBD, delta-8 THC, and other cannabinoids. The proposed rule is expected to establish potency limits, require adverse event reporting, and mandate third-party testing for contaminants. FDA will accept comments for 60 to 90 days, with a final rule projected for mid-2027 according to the July 2026 agenda. The IRS has not committed to a specific date for tax guidance but agency officials said in June 2026 that guidance would be issued within 90 days of the DEA's final rescheduling rule taking effect. The guidance will address whether cannabis businesses can immediately begin deducting ordinary business expenses or must wait until the beginning of the next tax year, a distinction worth billions of dollars in aggregate tax liability. The next Federal Rulemaking Agenda is scheduled for publication in December 2026, with OMB required to update all entries and add new rulemaking proceedings initiated since July. Cannabis stakeholders will monitor whether FinCEN adds a banking rule entry, whether DOJ addresses interstate commerce, and whether the DEA includes any follow-on rules addressing cultivation quotas, research licenses, or international treaty obligations under the Single Convention on Narcotic Drugs.

Further Reading: Primary Sources and Official Documents

• Unified Agenda of Federal Regulatory and Deregulatory Actions, Office of Management and Budget, https://www.reginfo.gov/public/do/eAgendaMain
• Administrative Procedure Act, 5 U.S.C. §§ 551-559, https://www.govinfo.gov/content/pkg/USCODE-2021-title5/pdf/USCODE-2021-title5-partI-chap5.pdf
• Regulatory Flexibility Act, 5 U.S.C. §§ 601-612, https://www.sba.gov/sites/default/files/advocacy/Reg-Flex-Act.pdf
• Executive Order 12866: Regulatory Planning and Review (September 30, 1993), https://www.archives.gov/files/federal-register/executive-orders/pdf/12866.pdf
• Congressional Review Act, 5 U.S.C. §§ 801-808, https://www.govinfo.gov/content/pkg/PLAW-104publ121/pdf/PLAW-104publ121.pdf
• Controlled Substances Act, 21 U.S.C. § 811 (Scheduling Authority), https://www.govinfo.gov/content/pkg/USCODE-2021-title21/pdf/USCODE-2021-title21-chap13-subchapI-partB-sec811.pdf
• DEA Notice of Proposed Rulemaking: Rescheduling of Cannabis, 89 Fed. Reg. 44,594 (May 21, 2024), https://www.federalregister.gov/documents/2024/05/21/2024-10006/schedules-of-controlled-substances-rescheduling-of-marijuana
• Office of Information and Regulatory Affairs, OMB, https://www.whitehouse.gov/omb/information-regulatory-affairs/
• Federal Register: Official Daily Publication, https://www.federalregister.gov/
• George Washington University Regulatory Studies Center: Tracking the Rulemaking Agenda, https://regulatorystudies.columbian.gwu.edu/
• FinCEN Guidance: BSA Expectations Regarding Marijuana-Related Businesses (February 14, 2014), https://www.fincen.gov/sites/default/files/shared/FIN-2014-G001.pdf
• National Cannabis Industry Association: Federal Policy Resources, https://thecannabisindustry.org/policy-federal/