TPI Portal Guide

Who Must Use the TPI Portal

All of the following must complete TPI disclosures:

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

Direct and indirect interests must be disclosed, including ownership, control, revenue rights, contract-based influence, and qualifying Goods & Services providers.

What the Portal Collects

The portal gathers comprehensive information about:

• Identification and contact details
• Ownership percentages and structures
• Financial rights, revenue share, and compensation
• Loans, promissory notes, and repayment terms
• Goods & Services agreements
• Officers, managers, and decision-makers
• Household relationships tied to financial influence
• Parent entities and chains of ownership
• Supporting documents for financial or management rights

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

Individual TPI Requirements

Individuals must disclose:

• Legal name and identifying information
• Contact information 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 control, influence, or ability to restrict business activities

OCM uses this information to determine TPI status, license control, and financial thresholds.

Entity TPI Requirements

Entities must disclose:

• Legal name, structure, and EIN
• Formation documents (operating agreement, bylaws, articles)
• 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 must be accounted for in entity disclosures.

Applicant Responsibilities

Applicants must:

• List every TPI (individual and entity)
• Upload ownership charts and organizational documents
• Provide all agreements tied to ownership, revenue, or control
• Ensure portal filings match the license application
• Certify no undisclosed individuals or entities exert influence

OCM compares applications to portal entries; mismatches can cause deficiency notices or denials.

How OCM Evaluates Submissions

OCM reviews TPI disclosures to check:

• Direct or indirect control
• Compensation exceeding the 10/50/250 rule
• Financial or controlling interest via Goods & Services contracts
• Compliance with vertical and horizontal ownership rules
• Full disclosure of individuals behind entities
• Document consistency across all TPIs

Common deficiency reasons include missing documents, inconsistent information, or incomplete ownership chains.

Updating TPI Information

Licensees must update the portal when:

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

OCM provides Interim TPI Change Request Guidance for processing temporary changes. Failure to update TPI information is a compliance violation.

Common Portal Issues

Frequent issues reported by OCM include:

• Listing TPIs in the application but not the portal
• Misclassifying Goods & Services providers as exempt
• Omitting passive investors above thresholds
• Leaving out individuals behind entity TPIs
• Unreported revenue rights or profit participation
• Missing or redacted contracts
• Conflicting information across TPIs
• Omitting household members sharing financial interests

Most issues are resolved by uploading complete documents and correcting inconsistencies.

Key Terms

True Party of Interest (TPI): Person or entity with ownership, control, influence, or financial interest

Direct or Indirect Financial or Controlling Interest (DIFCI): Person whose financial rights or influence meet OCM thresholds

Passive Investor (PI): Financial interest but no operational control

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

Related 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

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