In April 2026, the federal government moved medical cannabis to Schedule III of the Controlled Substances Act, the most significant change to marijuana’s federal status in more than 50 years. Over the summer, a Drug Enforcement Administration hearing took up the larger question of whether adult-use cannabis should follow, wrapping in mid-July with a recommendation still pending. For an industry that has spent more than a decade largely locked out of ordinary financial services, it read like a turning point. The banking rules, however, did not change.
Rescheduling recognizes that cannabis has accepted medical use and eases certain federal restrictions, but it does not create a safe harbor for the banks and credit unions that serve the industry. Schedule III is not legalization, and financial institutions remain bound by the same federal compliance obligations they carried before the order. The distance between what the change appears to mean and what actually governs cannabis banking is the environment operators continue to work in.
Black Hills Federal Credit Union has been serving cannabis businesses since 2023, and its experience offers a clear view of how financial institutions actually work with licensed operators, what those operators need from a banking partner, and where the system continues to fall short.
What Rescheduling Actually Changed
For the institutions that bank the industry, the April order had far less practical effect than the coverage suggested. Austin Trapp, a High Risk Business Specialist at BHFCU who works directly with the credit union’s cannabis members, describes it in plain terms.
“At this time, the rescheduling has not changed any banking practices in how we monitor our cannabis members,” Trapp said. The enhanced due diligence, the elevated reporting, the continuous license tracking, all of it continues exactly as it did before.
The order signaled possible future change without altering current …
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Author: High Times Partners / High Times