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Delinquent Payment Reporting: Cash on Delivery (C.O.D.) System
New York’s Cash on Delivery (C.O.D.) system is an enforcement mechanism used by the Office of Cannabis Management (OCM) to address unpaid supplier invoices. When a retailer fails to pay a licensed supplier, the supplier may report the delinquency to OCM. Once reported, the retailer is placed on the C.O.D. List and faces immediate purchasing restrictions until the issue is formally resolved.
What This Covers
- What the C.O.D. system is and why it exists
- How the C.O.D. List works
- How delinquent payments are reported
- How retailers are removed from the list
- How suppliers use the list to manage risk
The C.O.D. List
The C.O.D. List is maintained by OCM as an active enforcement tool.
When a retailer is placed on the list:
- They cannot receive cannabis products on credit
- All future purchases must be paid upfront
- They remain on the list until the reporting supplier submits a resolution
Retailers are not removed automatically.
Only the supplier who filed the delinquency can clear the listing.
Reporting a Delinquent Payment
Licensed suppliers may report a retailer when an invoice is not paid according to agreed terms.
Reports typically include:
- Supplier license information
- Retailer name and license number
- Invoice date
- Amount owed
- Documentation showing nonpayment
Accurate and complete documentation allows OCM to validate and process the report.
Submitting a Resolution
If the retailer pays the outstanding balance or resolves the dispute, the supplier must submit a resolution to OCM.
Resolution filings generally include:
- The delinquency report identifier
- Confirmation of payment (date, amount, method)
- Supplier license details
Until a resolution is submitted and accepted, the retailer remains on the C.O.D. List even if payment has occurred.
Viewing the C.O.D. List
Licensed suppliers may review the active C.O.D. List to:
- Verify a retailer’s status before extending credit
- Confirm whether a retailer has unresolved delinquencies
- Review the date and reason for a listing
- Assess credit risk before entering supply agreements
Regular review helps suppliers avoid transactions with retailers who may not be able to pay.
What Operators Usually Miss
- Retailers cannot remove themselves from the list
- Partial payment does not clear a listing unless documented as resolved
- C.O.D. status affects all suppliers, not just the reporting one
- Listings remain active until a formal resolution is filed
- Being on the list can disrupt inventory flow immediately
When This Comes Up
- When retailers miss payment deadlines
- During supplier credit reviews
- Before approving new wholesale relationships
- During audits or compliance reviews
- When retailers experience cash flow issues
What Happens If You Ignore This
For retailers:
- Loss of access to credit purchasing
- Delayed or blocked inventory deliveries
- Operational disruptions and revenue loss
- Increased scrutiny from suppliers and regulators
For suppliers:
- Unrecoverable receivables
- Increased financial risk
- Compliance issues if transactions proceed improperly
Related Pages
- Inventory Management and METRC
- Cannabis Banking
- Taxes, Fees, and Regulatory Reporting
- OCM Guidance
Source Material
