Who Must Use the TPI Portal in New York Cannabis?

Who Is Required to Complete a TPI Disclosure?

The following must complete TPI portal disclosures:

• Individual TPIs
• Entity TPIs
• Applicants
• Licensees with ownership, management, or financial changes

Direct and indirect interests must be disclosed.

This includes:

• Equity ownership
• Revenue rights
• Profit participation
• Contract-based influence
• Qualifying Goods & Services providers
• Loan agreements that create financial or operational control

If money, control, or influence is involved, it must be evaluated.

‍

What the TPI Portal Collects

The TPI Portal gathers detailed information about:

• Identification and contact information
• Ownership percentages and structures
• Revenue share and compensation rights
• Loans and promissory notes
• Goods & Services agreements
• Officers, managers, and decision-makers
• Household relationships tied to financial influence
• Parent entities and ownership chains
• Supporting documentation for financial or management rights

All applicants must certify that the information submitted is complete and accurate.

OCM compares portal filings against license applications.

‍

Individual TPI Disclosure Requirements

Individuals must disclose:

• Legal name and identifying information
• Contact details and residence history
• Employment history
• Ownership percentage or influence description
• Rights to revenue, profit, repayment, or compensation
• Management agreements or operational authority
• Goods & Services agreements
• Cannabis interests in other states
• Any ability to influence or restrict business activity

OCM uses this information to evaluate control, compensation thresholds, and eligibility.

‍

Entity TPI Disclosure Requirements

Business entities must disclose:

• Legal name, structure, and EIN
• Formation documents (Operating Agreement, Bylaws, Articles of Incorporation)
• Certificates of Good Standing
• Ownership charts and full organizational structure
• Officers, directors, and controlling individuals
• All persons behind the entity (look-through disclosure)
• Contracts, loans, and financial arrangements
• Related or parent companies
• Compensation and revenue rights

Every individual with ownership or control behind an entity must be disclosed.

Entity filings must match supporting documentation.

‍

Applicant Responsibilities

Applicants must:

• List every individual and entity TPI
• Upload ownership charts and organizational documents
• Provide all agreements tied to ownership, revenue, or control
• Ensure TPI Portal entries match the license application
• Certify that no undisclosed person exerts influence

Inconsistencies between the application and the portal commonly trigger deficiency notices.

‍

How OCM Evaluates TPI Submissions

OCM reviews disclosures to determine:

• Direct or indirect control
• Compensation exceeding the 10 / 50 / 250 thresholds
• Financial or controlling interest through Goods & Services agreements
• Compliance with vertical and horizontal ownership limits
• Whether all individuals behind entity structures are disclosed
• Consistency across documentation

Incomplete ownership chains are a common issue.

‍

When TPI Information Must Be Updated

Licensees must update the TPI Portal when:

• Ownership changes
• New contracts affect control or compensation
• New TPIs join
• Financial arrangements change
• Management authority shifts
• Legal names or addresses change
• A TPI leaves the business

Failure to update portal information is a compliance violation.

OCM may require an Interim TPI Change Request during transition periods.

‍

Common TPI Portal Issues

Frequent problems include:

• Listing TPIs in the application but not in the portal
• Misclassifying Goods & Services providers as exempt
• Omitting passive investors above financial thresholds
• Failing to disclose individuals behind entity TPIs
• Not reporting revenue-sharing arrangements
• Uploading incomplete or redacted contracts
• Conflicting information across multiple TPIs
• Not disclosing household members with shared financial interests

‍

Key Terms

True Party of Interest (TPI)
A person or entity with ownership, control, influence, or financial interest in a cannabis license.

Direct or Indirect Financial or Controlling Interest (DIFCI)
A person whose financial rights or influence meet OCM disclosure thresholds.

Passive Investor (PI)
An individual with financial interest but no operational control, who may still qualify as a TPI if thresholds are met.

10 / 50 / 250 Rule
TPI status is triggered if annual compensation exceeds 10% of gross revenue, 50% of net profits, or $250,000.

‍

Related TPI Section Pages

• TPI Disclosure Requirements
• Ownership & Control Restrictions
• Goods & Services Agreements
• TPI Changes & Updates
• TPI Main Page

Source Material

• OCM TPI Hub
• TPI Portal FAQ
• Retailer TPI FAQ
• Supply TPI FAQ
• Interim TPI Change Request Guidance

‍