I work for an insurance company and I am responsible for monitoring the federal and state law dichotomy with regard to cannabis.  My question is one seeking validation of what I believe to be the current situation -- my read of the current law framework is that while the 2018 Farm Bill has legalized hemp production/processing, the regulatory authority to implement that law resides with the USDA, which has not yet adopted any State plan for the production/processing of Hemp and the USDA is seeking input from stakeholders as part of their regulation-making process.  In the interim and for the 2019 planting season, States can continue operating under authorities of the 2014 Farm Bill, which allows States to implement a pilot program for the growth and cultivation of hemp.

Thus, what could be considered “legal” operations by an entity are those meeting the following 3 criteria, where the entity:  (i) is producing/processing hemp (which contains less than 0.3% THC level, as per 2018 Farm Bill); (ii) is domiciled and/or has its operations in a state allowing for a pilot program for hemp production under the 2014 Farm Bill; and (iii) has a license to grow, process hemp as granted under that pilot program.  Does that analysis criteria seem proper?

Also – is there a resource that outlines which States have a pilot program for hemp under the 2014 Farm Bill? 

Thank you for your time and attention to this matter and I look forward to the Webinar.

Regards,

Mark Boone 
The Hartford Steam Boiler Inspection and Insurance Co.