Phase 1 Portfolio review Weeks 1–4. Every California license in your portfolio is normalized into a single compliance-posture view alongside your out-of-state holdings — status, risk score, deficiency history, renewal window, and material-change exposure. We pressure-test the California footprint against the rest of your map: is the license mix economically aligned, are sites underutilized, does any one jurisdiction carry outsize enforcement risk. The deliverable is a decision memo covering remediation priorities, expansion or divestiture candidates, and the regulatory-risk constraints California places on your broader strategy. Reviewed with your CEO, GC, and Head of Compliance in a single working session.
Phase 2 Compliance architecture alignment Weeks 4–10. Your corporate QMS, national SOP library, and compliance-dashboard schema are reviewed against our CLAPP framework and DCC’s actual evidentiary expectations. Where your national records already satisfy CCR Title 4 Division 19, we confirm it in writing. Where they don’t, we build a translation layer: California-specific addenda to national SOPs, crosswalk maps, and an exhibit index that an auditor, diligence team, or DCC inspector can navigate without a tour guide. Output: a California compliance map that lives inside your corporate architecture rather than alongside it.
Phase 3 California operations integration Week 10 onward. The retainer cadence goes live with a named principal, a standing weekly or biweekly call with your VP of Compliance, and a monthly California dashboard that feeds your portfolio-level reporting in the format your team already uses. Renewals, FIH changes under CCR 15023, material changes under CCR 15020, METRC reconciliations, and local authorization renewals all run inside the retainer. When your internal team pulls a portfolio-level report, California data is already there — correctly categorized, dated, and linked to source documents.
Phase 4 Federal-readiness positioning Ongoing, reviewed quarterly. Federal rescheduling, SAFE Banking, and potential interstate-commerce authorization each shift the operating environment on different timelines; none of them will move on day one. We position your California operations for incremental readiness: batch records drafted to 21 CFR Part 111, ownership and FIH architecture mapped to FinCEN BSA reporting, supply-chain documentation compatible with interstate commerce, and QMS maintained to ISO 22000 rather than minimal CCR compliance. When the federal posture moves, your California platform is ready to scale across state lines — not rebuilt from the ground up.
