_{*Ken Griffin, CEO and Founder of Citadel}

Every quarter, institutions managing over $100 million in qualifying assets must file 13F reports with the SEC, disclosing their positions and what has changed since the previous quarter. These filings are due within 45 days of quarter-end.

This quarter’s filings included some eyebrow-raising entries that might be the first tea leaves suggesting institutional investors are finally dipping their toes into publicly traded cannabis companies.

Cantor Fitzgerald disclosed a nearly $40 million position in Trulieve (NYSE: TRUL). Cantor Fitzgerald’s former CEO, Howard Lutnick, is now the U.S. Secretary of Commerce, and his two sons currently run the firm.

Another notable filing came from Wellington, the blue-chip investment firm, which disclosed a new position in Glass House (NYSE: GLAS). Wellington is generally known as a long-term, fundamentals-driven investor.

But the most surprising news by far was that Citadel invested in Village Farms (NASDAQ: VFF). Why was this surprising? In 2024, Citadel CEO Ken Griffin personally donated $15 million to the campaign that fought to defeat Florida’s adult-use cannabis initiative, and he even wrote an op-ed opposing legalization. A direct investment bearing his firm’s name, and by extension his signature, doesn’t happen without his approval, or at least his tacit sign-off.

It’s worth noting that all these positions are tiny in the grand scheme of institutional finance. Still, for the cannabis industry, this is genuinely new territory.

Cannabis has struggled through a brutal four-year bear market, and capital remains scarce. But for the first time, we’re starting to see institutions, blue-chip institutions, no less, begin to invest. This is changing thanks to the first meaningful federal reform the industry has ever seen, and because a few cannabis companies are now trading on U.S. exchanges.

The institutional barbarians may not be banging down the gates just yet, but they clearly appear to be checking things out with starter positions. As the industry awaits full adult-use rescheduling, this initial group of investors could be the start of something much bigger. If Ken Griffin’s Citadel is willing to invest, it may not be long before every institution follows suit.

The Mindset Value Fund gained 19.2% on a net basis in Q2 and is now flat for the year.

Consorcio Ara Continues to Transform

Consorcio Ara (Mexico: ARA) has continued its strong performance and is now up 40% year to date including dividends. ARA has been the greatest contributor to our performance this year. When a company, especially a microcap is undergoing substantial change there are few eyeballs and few people paying attention, especially if past performance was poor.

ARA used to be considered a value trap. Sure, there was a lot of value, and the company was sitting on a land bank, but the company was under-earning its cost of capital and all that value seemed trapped without any growth, any asset sales, big dividends or substantial buybacks. But for the past 18 months, new management has been transforming this land bank heavy company into a growth engine and cash generating machine.

One excellent example of the sea change in the company is its cash conversion cycle. This is the time it takes for the company to convert assets into cash. Suddenly, last year, deep in the company’s earnings report, ARA started providing investors this information. The data not only gives a clue as to how management thinks about what is important, but its progress.

The company just reported its Q2 earnings, and they also announced that free cash flow jumped 45% year over year to approximately MX$379 million of free cash flow for the first half of 2026. And this may be just the beginning, in the next 3+ years, management believes they can drive another 30% reduction, which would unlock about MX$3.8 billion of cash, which would represent almost two-thirds of what the company’s market cap is right now.

Further, ARA announced a first joint venture with another company, in which the partner is providing the land, thus limiting the upfront investment. ARA used to buy all the land it builds on, so this is new for the company. The new management promised that they were now going to focus on capital returns and return on equity and this kind of action is definitive proof that they are delivering on their promise.

The company’s transformation is just starting to take hold, and this is exactly the kind of substantial changes we have been waiting for. Revenue is now growing at a double-digit rate and yet despite a strong first half rally the stock trades at 6.6 times trailing earnings and 37% of book value. We think the stock can go materially higher and are happy to collect dividends and sit back and wait as value is unlocked by management.

Adult-Use Rescheduling Hearing Finishes — What’s Next?

The DEA concluded its two-week rescheduling hearing on July 15th. The DEA judge has given the testifying parties until August 17th to submit follow-up briefs for consideration. We think the rescheduling order will follow closely after that August 17th date, and we expect a decision by the end of September. While anything can happen, we believe adult-use cannabis will be rescheduled just like medicinal cannabis by the DEA and/or the Department of Justice.

We think adult-use rescheduling would have a meaningful and very positive impact on our portfolio companies, which are on the cusp of an inflection. Several of our companies are turning on assets that were funded and built over the last twelve to twenty-four months and are moving from investment mode into revenue and cash-flow mode. Grown Rogue (OTC: GRUSF) began cultivation in Illinois, continues ramping up in New Jersey, and will soon commence operations in Minnesota, which has the highest cannabis prices in the country. LEEF (OTC: LEEEF) continues its expansion of Salisbury Canyon Ranch and just announced the purchase of a processing facility that will allow it to double its output. Vireo (OTC: VREOF) continues its roll-up at a dizzying pace, and we believe it may already be the third-largest cannabis company in the world. Uncle Arnie’s continues to outperform its projections every month.

Adult-use rescheduling should allow more capital to enter the industry, meaning better debt-financing terms, greater access to capital, and, for some of our companies, the potential to list on U.S. stock exchanges.

It’s important to note that simply listing on a U.S. exchange does not automatically mean a company’s valuation will go up. In fact, we’ve seen two U.S. plant-touching companies shift to a New York Stock Exchange listing thanks to medical cannabis being rescheduled, and their stock prices and valuations went down.

We believe that in one of these cases, the company (Trulieve: TRUL) is showing little if any growth and has laid out no specific plan to grow in the future. The other company (Glass House: GLAS) ran sharply higher in anticipation of its NYSE listing and, despite pulling back, still trades north of 20 times 2027 estimates.

What excites us is that we believe we are invested in true growth engines trading at remarkably low valuations. One of our companies is trading at possibly two to three times forward cash-flow estimates. Others are growing at near-triple-digit rates. We continue to believe there is tremendous mispricing within the cannabis industry, because there are very few institutional players and very few people doing real due diligence.

When adult-use rescheduling is finalized, we think sophisticated investors will start to enter the space. The first thing they will focus on is unit-level economics, competitive advantages, and companies that have built growth platforms that can be replicated in new markets. We believe that in a rescheduled world, our companies should soar in value compared to where they trade today.

Uncle Arnie’s Raises an Additional $2 Million

Uncle Arnie’s is simply crushing it.

The company is winning on two fronts: selling low-dose hemp beverages through liquor stores and cannabis beverages through dispensaries. While hemp sales have taken the company to another level, I want to focus your attention on how dispensary sales have taken off since we first invested.

Uncle Arnie’s dispensary sales have tripled since 2023, growing at a 44% CAGR (compound annual growth rate).

The dispensary channel is notoriously difficult, especially for beverages. First, dispensaries aren’t set up for drinks — most have limited refrigeration and limited storage for bulky products. Second, you largely must win dispensary by dispensary; there are few large chains and few, if any, large distributors like those found in the conventional beverage market. Finally, there is broad financial distress and persistent payment challenges across the dispensary market.

This is why Uncle Arnie’s success in dispensaries is so remarkable — and why it matters so much: even if there is no reprieve from the hemp ban by November, Uncle Arnie’s should be able to continue growing quickly in the dispensary channel and expanding into new states.

Regardless of what happens in November, we believe our Uncle Arnie’s investment will be very successful.

Capital is scarce in cannabis, and it’s even scarcer in anything cannabis-related — let alone a category like hemp beverages, which is staring down the barrel of that November ban. So, it’s quite a statement that Uncle Arnie’s was just able to close an oversubscribed $2 million round of fresh capital in a reopening of its Series A financing. The round was led by board member and Boston Beer founding partner Harry Rubin and his partners. Investors should read this as a massive vote of confidence from a beverage-industry veteran who knows the company intimately. Uncle Arnie’s management participated as well, as did the Mindset Uncle Fund. We did not invest additional capital from the Mindset Value Fund.

While there are numerous bills seeking to protect and regulate hemp rather than ban it — and a White House push for a solution — we believe Uncle Arnie’s is well positioned to succeed no matter what happens. Uncle Arnie’s already carries one of the healthiest balance sheets in the industry. This fresh capital, raised with minimal dilution, allows the company to stay aggressive while competitors retreat.

LEEF Doubles Capacity with Processing Acquisition

We invested in LEEF earlier this year to help develop the remainder of Salisbury Canyon Ranch (SCR). The company is making great progress and appears to be under budget and on schedule. At full build-out across its currently permitted 130 acres, SCR should produce approximately 1.3 million pounds of dry biomass at under $8 a pound — enough to yield more than 47 million grams of distillate, or equivalent quantities of live resin and rosin at comparable input costs. LEEF is not standing still at that scale either: it is actively pursuing permits for roughly 100 additional acres beyond the current footprint, which at similar yields would add another 1 million pounds of biomass and 36 million grams of distillate to the pipeline.

LEEF should very shortly be the largest cannabis farm in the world, and it’s on pace to become the largest — and yet lowest-cost — cannabinoid producer in the world as well.

And fresh off the presses, LEEF announced an agreement to acquire and build out a processing facility. This is a bigger deal than it may sound. Under LEEF’s current arrangement, its processing partner takes fifty percent of every harvest as its fee, meaning only about half of the crop grown on SCR is available for LEEF to sell today. Once the processing facility is online in 2027, LEEF will keep the entire harvest. On a 2027 basis, management estimates this move alone should more than double the biomass available to LEEF — from roughly 690,000 pounds to about 1.38 million pounds — and could drive approximately $25 million of incremental revenue and $16 million of incremental EBITDA at the operation level, before accounting for any of the ancillary cost savings the company’s consultant has flagged.

But it’s not the cost and scale that make LEEF so compelling — it’s the fact that LEEF can produce these concentrates free of heavy metals and, most importantly, free of pesticides. Because SCR is surrounded on three sides by mountains and national forest, it doesn’t face the pesticide-drift problem that plagues most cannabis farms in California.

Recalls and reports of pesticide problems in cannabis continue to mount. Regulators in California just issued another recall for Stiizy, the largest vape brand in the state — not the first time pesticides have been found in Stiizy vapes.

I’d also encourage investors to read this Epoch Times article, which follows a sheriff in Siskiyou County, California, on how Chinese pesticides are finding their way into the legal supply chain — and how California isn’t testing for all of them. The same problem is being exposed in Oklahoma and Colorado.

Cannabis can, in many ways, resemble the Wild West. Cannabis brands, retailers, and regulators may not care about long-term pesticide exposure — or may simply be struggling to enforce the rules — but I’ll tell you who must be waiting with bated breath for reform and legalization: class-action lawyers. I believe entire swaths of the cannabis industry are effectively untouchable as investments because of legacy pesticide-contamination issues, and that states like California could find themselves in the crosshairs as well for allowing this to persist.

We think the amount of clean, low-cost biomass and concentrates available is far smaller than most people realize. With adult-use rescheduling, interstate commerce and exports are far closer than before — perhaps even imminent. Once that happens, clean, pesticide-free supply may not be enough to meet demand. Further, when global CPG companies and strategics enter the space, a pesticide-free supply chain will be table stakes.

Ahead of legalization, international export, and eventually interstate commerce, we believe LEEF is fundamentally mispriced, with upside of more than ten times its current enterprise value of approximately $90 million.

Summary

We believe are set up for a very exciting back half of the year. Our portfolio companies are seeing accelerating growth and there is very positive federal reform that should pay big dividends to our cannabis investments as the year unfolds. Thank you so much for your support and trust.

As always, please reach out with any questions or comments.

Sincerely,

Aaron M. Edelheit

The Mindset Value Wellness Fund gained 17.3% on a net basis during Q2 and is down 8.1% for the year.

Adult-Use Rescheduling Hearing Finishes — What’s Next?

The DEA concluded its two-week rescheduling hearing on July 15th. The DEA judge has given the testifying parties until August 17th to submit follow-up briefs for consideration. We think the rescheduling order will follow closely after that August 17th date, and we expect a decision by the end of September. While anything can happen, we believe adult-use cannabis will be rescheduled just like medicinal cannabis by the DEA and/or the Department of Justice.

We think adult-use rescheduling would have a meaningful and very positive impact on our portfolio companies, which are on the cusp of an inflection. Several of our companies are turning on assets that were funded and built over the last twelve to twenty-four months and are moving from investment mode into revenue and cash-flow mode. Grown Rogue (OTC: GRUSF) began cultivation in Illinois, continues ramping up in New Jersey, and will soon commence operations in Minnesota, which has the highest cannabis prices in the country. LEEF (OTC: LEEEF) continues its expansion of Salisbury Canyon Ranch and just announced the purchase of a processing facility that will allow it to double its output. Vireo (OTC: VREOF) continues its roll-up at a dizzying pace, and we believe it may already be the third-largest cannabis company in the world. Uncle Arnie’s continues to outperform its projections every month.

Adult-use rescheduling should allow more capital to enter the industry, meaning better debt-financing terms, greater access to capital, and, for some of our companies, the potential to list on U.S. stock exchanges.

It’s important to note that simply listing on a U.S. exchange does not automatically mean a company’s valuation will go up. In fact, we’ve seen two U.S. plant-touching companies shift to a New York Stock Exchange listing thanks to medical cannabis being rescheduled, and their stock prices and valuations went down.

We believe that in one of these cases, the company (Trulieve: TRUL) is showing little if any growth and has laid out no specific plan to grow in the future. The other company (Glass House: GLAS) ran sharply higher in anticipation of its NYSE listing and, despite pulling back, still trades north of 20 times 2027 estimates.

What excites us is that we believe we are invested in true growth engines trading at remarkably low valuations. One of our companies is trading at possibly two to three times forward cash-flow estimates. Others are growing at near-triple-digit rates. We continue to believe there is tremendous mispricing within the cannabis industry, because there are very few institutional players and very few people doing real due diligence.

When adult-use rescheduling is finalized, we think sophisticated investors will start to enter the space. The first thing they will focus on is unit-level economics, competitive advantages, and companies that have built growth platforms that can be replicated in new markets. We believe that in a rescheduled world, our companies should soar in value compared to where they trade today.

Uncle Arnie’s Raises an Additional $2 Million

Uncle Arnie’s is simply crushing it.

The company is winning on two fronts: selling low-dose hemp beverages through liquor stores and cannabis beverages through dispensaries. While hemp sales have taken the company to another level, I want to focus your attention on how dispensary sales have taken off since we first invested.

Uncle Arnie’s dispensary sales have tripled since 2023, growing at a 44% CAGR (compound annual growth rate).

The dispensary channel is notoriously difficult, especially for beverages. First, dispensaries aren’t set up for drinks — most have limited refrigeration and limited storage for bulky products. Second, you largely must win dispensary by dispensary; there are few large chains and few, if any, large distributors like those found in the conventional beverage market. Finally, there is broad financial distress and persistent payment challenges across the dispensary market.

This is why Uncle Arnie’s success in dispensaries is so remarkable — and why it matters so much: even if there is no reprieve from the hemp ban by November, Uncle Arnie’s should be able to continue growing quickly in the dispensary channel and expanding into new states.

Regardless of what happens in November, we believe our Uncle Arnie’s investment will be very successful.

Capital is scarce in cannabis, and it’s even scarcer in anything cannabis-related — let alone a category like hemp beverages, which is staring down the barrel of that November ban. So, it’s quite a statement that Uncle Arnie’s was just able to close an oversubscribed $2 million round of fresh capital in a reopening of its Series A financing. The round was led by board member and Boston Beer founding partner Harry Rubin and his partners. Investors should read this as a massive vote of confidence from a beverage-industry veteran who knows the company intimately. Uncle Arnie’s management participated as well, as did the Mindset Uncle Fund. We did not invest additional capital from the Mindset Value Wellness Fund.

While there are numerous bills seeking to protect and regulate hemp rather than ban it — and a White House push for a solution — we believe Uncle Arnie’s is well positioned to succeed no matter what happens. Uncle Arnie’s already carries one of the healthiest balance sheets in the industry. This fresh capital, raised with minimal dilution, allows the company to stay aggressive while competitors retreat.

LEEF Doubles Capacity with Processing Acquisition

We invested in LEEF earlier this year to help develop the remainder of Salisbury Canyon Ranch (SCR). The company is making great progress and appears to be under budget and on schedule. At full build-out across its currently permitted 130 acres, SCR should produce approximately 1.3 million pounds of dry biomass at under $8 a pound — enough to yield more than 47 million grams of distillate, or equivalent quantities of live resin and rosin at comparable input costs. LEEF is not standing still at that scale either: it is actively pursuing permits for roughly 100 additional acres beyond the current footprint, which at similar yields would add another 1 million pounds of biomass and 36 million grams of distillate to the pipeline.

LEEF should very shortly be the largest cannabis farm in the world, and it’s on pace to become the largest — and yet lowest-cost — cannabinoid producer in the world as well.

And fresh off the presses, LEEF announced an agreement to acquire and build out a processing facility. This is a bigger deal than it may sound. Under LEEF’s current arrangement, its processing partner takes fifty percent of every harvest as its fee, meaning only about half of the crop grown on SCR is available for LEEF to sell today. Once the processing facility is online in 2027, LEEF will keep the entire harvest. On a 2027 basis, management estimates this move alone should more than double the biomass available to LEEF — from roughly 690,000 pounds to about 1.38 million pounds — and could drive approximately $25 million of incremental revenue and $16 million of incremental EBITDA at the operation level, before accounting for any of the ancillary cost savings the company’s consultant has flagged.

But it’s not the cost and scale that make LEEF so compelling — it’s the fact that LEEF can produce these concentrates free of heavy metals and, most importantly, free of pesticides. Because SCR is surrounded on three sides by mountains and national forest, it doesn’t face the pesticide-drift problem that plagues most cannabis farms in California.

Recalls and reports of pesticide problems in cannabis continue to mount. Regulators in California just issued another recall for Stiizy, the largest vape brand in the state — not the first time pesticides have been found in Stiizy vapes.

I’d also encourage investors to read this Epoch Times article, which follows a sheriff in Siskiyou County, California, on how Chinese pesticides are finding their way into the legal supply chain — and how California isn’t testing for all of them. The same problem is being exposed in Oklahoma and Colorado.

Cannabis can, in many ways, resemble the Wild West. Cannabis brands, retailers, and regulators may not care about long-term pesticide exposure — or may simply be struggling to enforce the rules — but I’ll tell you who must be waiting with bated breath for reform and legalization: class-action lawyers. I believe entire swaths of the cannabis industry are effectively untouchable as investments because of legacy pesticide-contamination issues, and that states like California could find themselves in the crosshairs as well for allowing this to persist.

We think the amount of clean, low-cost biomass and concentrates available is far smaller than most people realize. With adult-use rescheduling, interstate commerce and exports are far closer than before — perhaps even imminent. Once that happens, clean, pesticide-free supply may not be enough to meet demand. Further, when global CPG companies and strategics enter the space, a pesticide-free supply chain will be table stakes.

Ahead of legalization, international export, and eventually interstate commerce, we believe LEEF is fundamentally mispriced, with upside of more than ten times its current enterprise value of approximately $90 million.

Summary

We are expecting an action-packed second half of the year. There should be a lot of regulatory news, from rescheduling to whether the hemp ban stays in place. Also, as our core investments turn on assets and expand, they should start to report accelerating growth in an industry that has struggled to show any growth at all. We see a long runway of growth for our portfolio companies and think they are fundamentally mispriced.

Reform is the beginning of the game, not the end. With meaningful catalysts, strong expected growth, and improving earnings across our portfolio, we remain optimistic about both the near-term and long-term future.

As always, please reach out with any questions or comments.

Sincerely,

Aaron M. Edelheit

Growth has been challenging for the cannabis industry. Price declines, oversupply, and a thriving illicit market have produced an industry with little to no growth.

Pundits and advisors have hyped the international opportunity, but our research shows that market is roughly the size of Missouri’s — and while interesting, prices are falling. For larger companies with over $1 billion in market cap, the international market may not move the needle much.

Others have cited a potential hemp ban as a catalyst. A ban may help at the margin, but hemp is likely just displacing the illicit market, given how easy it is to purchase and the ability to pay by credit card.

Which brings us to the biggest potential unlock for the cannabis industry — one that seemed far off until Trulieve suddenly listed on the NYSE: credit cards.

Explosive Growth Followed Fast Food Chains Accepting Credit Cards

It’s hard to imagine today, but just a few decades ago, major fast-food chains did not accept credit cards. At the time, a dial-up modem could take up to a minute to approve a transaction — an unacceptable delay for an industry built on speed. The widespread adoption of high-speed internet eventually solved that problem, and fast-food chains began broadly accepting credit cards in the early 2000s. Once they did, sales surged.

Wendy’s reported that average basket sizes were 35% higher with card payments than cash. Subway saw transaction sizes double. McDonald’s net income increased more than threefold.

It turns out that not being limited by the cash in your pocket dramatically increases your willingness to spend.

Today, even as credit cards dominate retail nearly everywhere else, cash remains king in cannabis. That may be about to change. Consider: Trulieve (NYSE: TRLV) is a plant-touching medical cannabis company now listed on the NYSE — yet customers still can’t use a credit card in their dispensaries. Like the exchanges, card networks are governed by private network rules rather than federal law, giving them discretion to allow cannabis transactions based on their own risk assessment. The fact that cannabis companies can now list on major exchanges sends a strong signal that perceived risk is falling.

We believe credit cards may soon be permitted in cannabis — and the potential impact is under-appreciated by investors.

The Potential Impact of Credit Cards

Start with the consumer. Over 60% of Americans live paycheck to paycheck. Cannabis use skews toward lower-income consumers, and the industry is dominated by heavy users. Put those three facts together and the conclusion is hard to avoid: cannabis basket sizes should rise significantly once consumers can pay by card.

Some of that lift will come from impulse purchases, but there’s a rational economic argument too. At High Tide in Canada, 40% of sales are ounce packages, which carry meaningfully better per-gram pricing. For heavy users, buying in bulk is simply the smart move — the only obstacle is having enough cash on hand.

Nor will the benefits be limited to those living paycheck to paycheck. Cash is expensive and slow. ATM fees run around 5% per withdrawal, and the extra trip adds friction and time at the register. Card acceptance would give the legal market a real advantage over the black market and finally bring it to parity with the intoxicating hemp market, which already accepts cards.

Reducing cash also has meaningful benefits for retailers. Dispensaries carrying large amounts of cash are attractive targets for armed robbery, putting employees at risk. Beyond safety, cash is costly to handle, secure, and transport — one study estimated that cost as high as 9% of revenue, a significant burden in competitive markets where thin margins create accounts-payable problems that ripple through the supply chain.

We believe sales could rise 10–30% or more once card payments are accepted — consistent with the fast-food comparison above. Data from the cannabis industry points in the same direction. According to Flowhub, average order value with debit cards was 22% higher than with cash. The Cantaloupe Micropayment Trends Report shows the same pattern across retail: cashless transactions drive higher spending, with vending machine ticket sizes running 37% higher when cards are used.

Flowhub reports that cash still accounts for 60% of total cannabis spending — over $18 billion. The Federal Reserve puts cash’s average share in retail at just 15%, suggesting roughly $15 billion could eventually shift to cards. That translates to a potential sales increase of $1.5 to $4.5 billion or more. Even the low end of that range is approximately the size of the entire European cannabis market. Volumes should rise, the legal market should reclaim share from the illicit one, and near-term pricing should improve — particularly in the most competitive markets like California, Oregon, and Michigan.

Conclusion

Cannabis has spent years waiting on federal catalysts, and rescheduling and exchange listings are significant ones. But close behind those developments is a quieter, deeply practical change: the potential arrival of credit cards. We’ve seen what going cashless did to spending in fast food and across retail broadly, and we see no reason cannabis — a category defined by heavy, lower-income, paycheck-to-paycheck consumers — would behave any differently.

When the cards finally arrive, the retail surge could surprise even optimistic observers. And with that surge could come the growth the entire cannabis industry needs to capture investors’ attention.

Trulieve, one of the largest multi-state operators (MSOs), began trading on the NYSE today under the ticker TRLV. The stock finished slightly down on five times its average volume during a broadly negative day in the markets.

The speed at which Trulieve was able to list on a major exchange surprised nearly everyone, and it is largely thanks to the White House’s rescheduling of medical cannabis. Once medical cannabis was moved to Schedule III, Trulieve was uniquely positioned to separate its adult-use operations from its medical cannabis business — a distinction made easier by the fact that most of the company’s sales were already medical. Congratulations to Trulieve and its CEO, Kim Rivers — this is truly a pioneering step toward bringing cannabis into the mainstream financial system.

And so here we are for the first time, a plant-touching U.S. cannabis company is trading on a major exchange.

Now attention turns to adult-use rescheduling and the hearings scheduled from June 29th through July 15th. We believe that rescheduling adult-use cannabis should unlock the same access to major exchanges that medical rescheduling gave Trulieve.

We also believe the biggest beneficiaries of broader institutional capital and major exchange listings may not be the largest cannabis companies — many of which are struggling with growth, are concentrated in limited-license markets, and lack a clear path forward. Instead, the biggest winners may be smaller companies with strong growth trajectories, lean cost structures, and repeatable business models that have historically lacked the capital access enjoyed by their larger peers.

One example is Grown Rogue (OTC: GRUSF). The company is amid a substantial transformation, expanding from a two-state operator to a five-state operator while running at only 42% capacity utilization. As it brings that capacity online in limited-license states, growth, return on invested capital, and cash flow should improve significantly. We believe it is possible that Grown Rogue trades at 2.2 times the potential cash flow it could generate at full capacity — though that figure depends on pricing, which remains dynamic and faces ongoing long-term pressure. Regardless of where pricing settles in New Jersey, Illinois, and Minnesota, growth should accelerate as that capacity comes online, just as investors begin doing serious due diligence in the space and seek out low-cost, high-quality operators with a long runway ahead.

We believe Grown Rogue could qualify for a NASDAQ listing with a reverse split and adult-use rescheduling, and we continue to view the stock as materially mis-priced — and it is just one of several such opportunities across both public and private markets.

More Questions Than Answers for Trulieve and Others

Beyond the milestone of trading on a major exchange, the more interesting question is what Trulieve does with that liquidity and equity. Will they begin acquiring assets using publicly traded common stock? What is their strategic vision beyond their Florida footprint and the near-term tax savings of 280e going away? What are the second- and third-order effects of this listing? Will private equity and other corners of the financial world follow? I’ll address one potentially significant second-order effect in a separate post.

The cannabis landscape is shifting, and we believe substantial opportunity remains in the sector — particularly given how little institutional due diligence is currently being done and how few sophisticated investors are actively participating. This exchange listing is a meaningful signpost of what’s ahead. Don’t mistake the absence of an immediate surge for a lack of future upside — cannabis may be as compelling an opportunity as it has ever been.

So, we did what we always do at Mindset: deep-dive research. Our senior analyst, Fateh Mann, traveled to Thailand and Europe, meeting with cannabis companies across the supply chain — growers, EU-GMP facilities, distributors, and telehealth platforms.

What we found:

International markets are far smaller than anyone appreciates, growing more slowly than expected, with intensifying supply and competition — all pointing to much lower profitability ahead.

Everyone Wants a Piece of a Small Pie

Here’s the reality: the entire European cannabis market — well under $1.5B in 2025 — is currently smaller than the state of Missouri, a state most Europeans have likely never heard of.

Canada currently dominates European exports, but competition is heating up fast. We’ve spoken with talented cultivators in Thailand, Zimbabwe, and Colombia, where significant supply is being built with Europe in mind. Lesotho is emerging as a promising cultivation hub in Africa, and we have visited several Thai cultivation facilities being built by North American operators. Substantial supply and competition are building from very low-cost regions — for a market the size of one midwestern US state.

Germany consumed approximately 160 tons of cannabis at retail in 2025, or about 350,000 pounds. LEEF Brands’ (OTC: LEEEF) Salisbury Canyon Ranch at scale alone could supply Germany’s entire market.

The Pie Isn’t Growing Very Fast

After an initial burst of rapid growth, the market has slowed significantly. Pricing is also down 13% in just the first quarter of 2026. For US cannabis investors who have painfully experienced what happens to pricing in limited license states, this should sound oddly familiar.

Prohibition Partners projects the top three markets — Germany, the UK, and Poland — to grow at a combined rate of under 15% CAGR through 2030. On-the-ground operators corroborate this: the German market, roughly 70% of Europe in 2025, is expected to double over the next four to six years.

And remember — this is still cannabis, where growth rarely follows a linear path. Much of Germany’s prescription surge ran through telemedicine. The German Health Ministry has already floated a draft amendment that would sharply restrict it. If passed, this could not only slow growth but shrink the market.

Pricing Is Already Low — and Getting Lower

Bloomwell, a leading telemedicine platform, reports the average gram of German flower (~25% THC), inclusive of 19% VAT, is €4.52 ($5.26 USD). Excluding tax, that’s under $4.30 a gram, or roughly $15 an eighth — nearly a third of the price in Minnesota and below much of the US East Coast. Over 60% of volume is priced under $3.80 per gram (ex-tax), or $13.30 an eighth.

Wholesale is worse. Once you factor in shipping and EU-GMP certification, our channel checks put finished flower below $2 a gram — roughly $900 a pound. This is flower pricing, not biomass. Trim routinely sells for 5–10% of flower pricing.

Given the ongoing supply build, further price declines are likely. Add excess US supply entering a small market, and we expect prices to collapse.

Some of the Canadian LPs have enjoyed solid profit growth as early suppliers to the German market. That advantage is now under threat. We are decidedly bearish on the future profitability of some of the Canadian exporters, especially if the US enters the picture.

Cultivators Have Little Power

The German market is currently 95% flower, with heavy marketing and packaging restrictions. It takes many months from harvest before a consumer touches the product — by which point quality has already degraded. After many conversations, we found no evidence of brand loyalty in flower, which we have rarely seen even in North America. We are confident that won’t change.

A strict regulatory structure sits between pharmacies — Germany’s equivalent of dispensaries — and distributors. The core problem for cultivators, however, is that distributors control consumer access through their owned telemedicine platforms. Cultivators have little leverage, and everyone else in the chain knows it. Cantourage, one of Germany’s largest distributors (ETR: HIGH), told us they pay Canadian suppliers only after product has been sold — often six months later. The cash flow dynamics are brutal, yet cultivators have little choice but to accept these terms.

Conclusion

Is there an opportunity? Yes — but it will take longer than expected, as has been true of everything in cannabis, and it is unlikely to move the needle yet for any large cannabis company.

One interesting opportunity outside of flower is extracts, which today represent a tiny sliver of the European market. International markets should follow US consumption patterns, and extracts and concentrates should see tremendous growth. Extracts also carry a much longer shelf life, sparing distributors the concern of mold in aging inventory.

As the largest and lowest-cost producer in the most sophisticated, competitive, and discerning cannabis market in the world, we believe LEEF Brands (OTC: LEEEF) is well positioned to benefit from the global extract market. The pricing premium is substantial: a vape product with 80% THC retails at €80 ($92) in Germany, while higher-quality products sell for $20 in California.

LEEF is currently selling distillate for under $1 a gram; any increase in pricing or demand would make a meaningful difference even from modest international traction. If LEEF sells just 10% of its 2026 distillate production at $4 per gram, that’s an extra $10M in high margin revenue — highly significant for a company with an ~$80M enterprise value.

We’ve learned the hard way that in cannabis, things always take longer than expected. The international market is no different. At $30B, with several states yet to launch medical or recreational programs, the US remains the big prize — 20 times the size of international markets combined. At Mindset, we remain focused on the real prize in cannabis: the United States.

Warning: The following column is about a microcap company. Microcaps by definition can be illiquid and experience wild gyrations. It is important to do your own due diligence, rely on your own research and understand that microcaps can be very volatile. Please proceed reading using your highest levels of caution. That being said…

Mindset Capital now owns over 12% of LEEF Brands after leading the company’s latest financing round. Why would we take such a large stake in such a small company?

Here is why:

1. The financial impact of LEEF fully activating Salisbury Canyon Ranch next year is not yet reflected in the company’s valuation. Our own estimate is that cash flow should jump to $15 million per year once this ranch is brought online.

2. No cannabis company offers greater upside from interstate commerce or exports than LEEF, largely due to its tiny enterprise value of just $75 million relative to the potential of selling its product for as much as 8 times more in other states or countries. Consider that at full scale, every $0.10 per gram increase in distillate prices could generate as much as $7 million in additional annual cash flow for LEEF — and in New Jersey, prices are $7 per gram higher than in California.

3. Investors may not fully appreciate the sheer scale of what LEEF is building. The company is working towards being capable of producing approximately 2 million pounds of cannabis biomass and 70 million grams of vape distillate — and is actively working to expand that to as many as 4–5 million pounds of cannabis biomass and over 100 million grams of distillate. At that scale, LEEF could become the largest cannabis producer in the world.

This is why we now own such a large stake in LEEF and hold warrants to acquire even more. We believe LEEF’s stock price could increase more than 10 times from its current level.

As always, please do your own due diligence. This is a long-term holding for Mindset Capital and its investors. We have planted a flag in what we believe could be one of the most important cannabis companies in the world.

If you would like to research LEEF further, please check out our deep dive research report on the company:

LEEF Investment Memo

Mindset Value Fund Q1 2026 Investor Letter

The Mindset Value Fund lost 16.3% on a net basis in Q1.

Consorcio Ara is Proving that it is a Value Trap No More

Consorcio Ara (Mexico: ARA) jumped 30% in Q1 on the back of strong Q4 results, which were followed by great first quarter earnings that were reported in April.

We believe that the next generation leadership is driving substantial changes in the company. Revenue is now growing at more than 20% and cash flow by over 30%, yet the stock trades at 5 times trailing earnings and 32% of book value.

While we wait for this transformation to continue from a low return on equity business that was a value trap into a growth story and a big improvement in return on equity, we get paid a dividend. We continue to be very bullish on Ara, and it is now our second largest position in the fund.

Here is our long-form research report on the company if you want a deeper dive into the company: Consorcio Ara Research Report.

Trump Reschedules Medical Cannabis, Recreational Due Up on Deck

Last week, acting Attorney General Todd Blanche and the Department of Justice rescheduled medical cannabis to Schedule III and booked a final hearing on rescheduling adult-use cannabis, beginning June 29th and ending July 15th. While the path forward has created some confusion, this is the first major federal cannabis reform in history.

I could not be more excited about our investments in cannabis right now. To me, this rescheduling news is not the finish line where everyone suddenly gets rich, but the first pitch of the first game of the season.

What makes this news exciting is there is a profound absence of institutional players and private equity. There is simply little or no competition to invest in the best companies with durable long-term advantages. And for the first time, we finally have real regulatory change.

As fundamental analysts, there has never been a better time to do real research and invest in cannabis. We would ask anyone invested in cannabis or interested in investing to consider just some of the following questions:

1. What does it mean if there is a regulatory difference between medical cannabis and adult use?

2. What does it mean to register with the DEA?

3. Does registration allow the DEA to investigate how companies operate?

4. What if companies can now engage in interstate commerce for medicinal cannabis?

5. What happens to a cannabis company’s cash flow if there is interstate commerce?

These are just some of the questions to ask. But what about the one question that most existing cannabis investors ignore: what is a company’s cost to produce cannabis products? Few if any companies share such information. And I believe institutional investors will demand to understand how these businesses work.

It won’t happen overnight, but I believe institutional capital will enter this space. The cannabis industry is too attractive and its potential too great for professional investors, private equity, and institutional capital to ignore. And when those investors enter, things will change, especially when those investors conduct a dive deep into the real business fundamentals. They may be surprised by what they find. This is why we have been so selective in who and what we invest in.

While it may be fun to trade some volatile stocks, rescheduling won’t save faulty business models built on hype, limited licenses and handwaving. Rescheduling should lift a whole cohort of new companies who have worked on building durable competitive advantages for a national and international market. We believe we are investors in some of these companies.

In 2011, I stood on the courthouse steps in Atlanta, Georgia, bidding on foreclosed homes — stunned that there were no professional investors around. That all changed in the summer of 2012, when Colony and Blackstone showed up at the auctions. Valuations and dynamics shifted immediately.

The real game has finally begun, and we are ready.

Investing in LEEF and Pesticide Free Concentrates

One of the companies that we think is going to be a big winner in this new future is LEEF Brands (OTC: LEEEF).

LEEF Brands is California’s largest cannabis extract manufacturer, producing concentrates like distillate for vapes, live resin and rosin and over 100 different forms of concentrates for leading California brands like Kiva, Heavy Hitters (Mammoth), Wyld, Rove, and Jetty.

Research and due diligence have shown us that there is a pesticide problem in cannabis concentrates in California, and that investors are not aware of the severity of the problem.

In 2024, an LA Times investigation exposed a widespread contamination crisis in the world’s largest and most important cannabis market. Sixty percent of randomly sampled California cannabis products contained pesticides exceeding safety limits, including known carcinogens. Some vape cartridges tested positive for more than two dozen pesticide compounds. A follow-up investigation six months later found little had changed.

The root cause is structural. California is America’s agricultural heartland, and its conventional farms have applied heavy volumes of pesticides for decades. This leaves cannabis operations highly vulnerable to “pesticide drift”- winds carrying chemical residues from neighboring farms onto cannabis crops. The problem of pesticide drift is well-established in California and widely documented, including by official state agencies. As far back as 2019, the state officially confirmed that a cannabis harvest had been damaged by pesticide drift from a neighboring vineyard.

“There are certain times of the year I’m not going to get samples from certain regions, because those samples will be contaminated pesticides used in conventional agriculture. There’s no way to keep that out of the air. It’s not even a possibility.”- Jeff Gray, Owner at SC Labs, one the labs that partnered with the LA Times investigation.

Compounding the problem, cannabis is a powerful bio-accumulator that absorbs impurities and heavy metals from the soil. In fact, it is so effective at this that it was deployed to remediate the land around Chernobyl after the nuclear accident in Ukraine. In California, where now-banned pesticides were used extensively for decades, cannabis grown today may carry a legacy chemical burden from the soil itself, such as Chlordane - a pesticide that was banned in 1988 but has a long half-life.

Further, we believe that there may not be enough of a consistent supply of low-cost cannabis biomass and concentrates that is clean of pesticides and heavy metals for the eventual national US market, for medical cannabinoid products that may get medical reimbursement and for the very strict export market into Europe.

We think that the activation of LEEF’s Salisbury Canyon Ranch (SCR), a 1,900-acre property in remote northeastern Santa Barbara County in California is a key catalyst for LEEF. The immediate result is lowering LEEF’s own cost by up to 80% from purchasing biomass for $25 to $50 a pound and instead producing that biomass itself for $8 per pound. To show how much of a key catalyst this was, LEEF’s gross margins doubled upon turning on just 30% of SCR.

We project LEEF’s Adj EBITDA to grow from a small loss in 2025 to approximately $15M in 2027. On this alone and without interstate commerce or exports, we believe LEEF could be worth close to $0.40 per share, which could lead to our investment increasing by 200%+ in the next 12-18 months.

But an even more exciting future awaits as the company builds a platform that can produce any cannabinoid input at a cost, quality and scale that is unmatched in cannabis. The company at scale should one day be able to produce over 70 million grams of distillate. That’s enough to supply 60% of California’s vape market at a price no one else can match.

Consider that in California, LEEF is selling distillate for $1 a gram. That same gram sells for $4 in New York, $6 in Massachusetts and $8 in New Jersey.

Our analysis leads us to the believe that with the opportunity of interstate commerce or the ability to export, this microcap company has the chance to be worth more than $1 billion, versus its sub-$100 million enterprise value. In a scenario where the company could supply products to more lucrative national or overseas markets, it is possible that our investment has the potential to increase by more than ten times.

We are about to close a special purpose vehicle that is investing in the company’s equity that includes lucrative warrants. If you have interest, please let me know.

Grown Rogue Is Only Producing at 42% of Capacity

Grown Rogue (OTC: GRUSF) is licensed across five states - Oregon, Michigan, New Jersey, Illinois, and Minnesota - but today it is using only 42% of its total production capacity. Two of those five states haven’t produced a single pound of flower. A third state is at half its capacity. The company has been spending ahead of these opportunities and has yet to see the returns.

The business investors see today is a half-built machine. The question isn’t “what does Grown Rogue earn?” It’s “what does Grown Rogue earn when the lights are on in every room?”

Even at reasonably conservative prices, and an increase in current operating expenses, the company’s economics are very attractive and are the reason the company is now guiding to returns on incremental invested capital of 75%.

It has been painfully hard to be patient as Grown Rogue has retraced its big advance and has been under constant selling pressure from funds shutting down and few willing to do any work on the underlying unit level economics. All the while, Oregon and Michigan experienced a brutal price decline and New Jersey took longer than expected to fully activate.

But the wait is almost over. The final phase of the New Jersey facility is under construction, and the facility will soon be at full capacity. Illinois and Minnesota are in active development, with first harvests expected to start contributing to 2026 and ramp through 2027.

The company is turning the lights on a lot more cultivation capacity, and come this time next year, Grown Rogue should be a substantially larger and much more profitable company.

At today’s valuation, the market is pricing in what Grown Rogue earns at 42% utilization. It is not pricing in what the company earns when every cultivation room is running. That gap between $5M in EBITDA and $50M in EBITDA is the opportunity.

If you would like to play around with the assumptions made in this post, click on the link below and you can play around with cost and sales assumptions yourself. As always please do your own due diligence and rely on your research.

Grown Rogue Capacity Analysis Link

And one final note on Grown Rogue is that if there is ever interstate commerce, Grown Rogue should be one of the big beneficiaries. They are selling cannabis in Oregon for $600 a pound and in Michigan for $800, which would command much greater prices in other states. Also, they can grow a lot more outdoor cannabis in the Rogue Valley in Oregon, where conditions are perfect for growing outdoor cannabis. Not only is the full earnings power of Grown Rogue not being priced in, but the potential for interstate commerce is also not being priced in either.

Summary

We are set up for a very exciting back half of the year. Our portfolio companies are seeing accelerating growth and there is very positive federal reform that should pay big dividends to our cannabis investments as the year unfolds. Our performance has already been bouncing back in April, and we think there is much more to come. Thank you so much for your support and trust.

As always, please reach out with any questions or comments.

Sincerely,

Aaron M. Edelheit

******************************************

Mindset Value Wellness Fund Q1 2026 Investor Letter

The Mindset Value Wellness Fund lost 21.7% on a net basis during Q1.

Trump Reschedules Medical Cannabis, Recreational Due Up on Deck

Last week, acting Attorney General Todd Blanche and the Department of Justice rescheduled medical cannabis to Schedule III and booked a final hearing on rescheduling adult-use cannabis, beginning June 29th and ending July 15th. While the path forward has created some confusion, this is the first major federal cannabis reform in history.

I could not be more excited about our investments in cannabis right now. To me, this rescheduling news is not the finish line where everyone suddenly gets rich, but the first pitch of the first game of the season.

What makes this news exciting is there is a profound absence of institutional players and private equity. There is simply little or no competition to invest in the best companies with durable long-term advantages. And for the first time, we finally have real regulatory change.

As fundamental analysts, there has never been a better time to do real research and invest in cannabis. We would ask anyone invested in cannabis or interested in investing to consider just some of the following questions:

1. What does it mean if there is a regulatory difference between medical cannabis and adult use?

2. What does it mean to register with the DEA?

3. Does registration allow the DEA to investigate how companies operate?

4. What if companies can now engage in interstate commerce for medicinal cannabis?

5. What happens to a cannabis company’s cash flow if there is interstate commerce?

These are just some of the questions to ask. But what about the one question that most existing cannabis investors ignore: what is a company’s cost to produce cannabis products? Few if any companies share such information. And I believe institutional investors will demand to understand how these businesses work.

It won’t happen overnight, but I believe institutional capital will enter this space. The cannabis industry is too attractive and its potential too great for professional investors, private equity, and institutional capital to ignore. And when those investors enter, things will change, especially when those investors conduct a dive deep into the real business fundamentals. They may be surprised by what they find. This is why we have been so selective in who and what we invest in.

While it may be fun to trade some volatile stocks, rescheduling won’t save faulty business models built on hype, limited licenses and handwaving. Rescheduling should lift a whole cohort of new companies who have worked on building durable competitive advantages for a national and international market. We believe we are investors in some of these companies.

In 2011, I stood on the courthouse steps in Atlanta, Georgia, bidding on foreclosed homes — stunned that there were no professional investors around. That all changed in the summer of 2012, when Colony and Blackstone showed up at the auctions. Valuations and dynamics shifted immediately.

The real game has finally begun, and we are ready.

Investing in LEEF and Pesticide Free Concentrates

One of the companies that we think is going to be a big winner in this new future is LEEF Brands (OTC: LEEEF).

LEEF Brands is California’s largest cannabis extract manufacturer, producing concentrates like distillate for vapes, live resin and rosin and over 100 different forms of concentrates for leading California brands like Kiva, Heavy Hitters (Mammoth), Wyld, Rove, and Jetty.

Research and due diligence have shown us that there is a pesticide problem in cannabis concentrates in California, and that investors are not aware of the severity of the problem.

In 2024, an LA Times investigation exposed a widespread contamination crisis in the world’s largest and most important cannabis market. Sixty percent of randomly sampled California cannabis products contained pesticides exceeding safety limits, including known carcinogens. Some vape cartridges tested positive for more than two dozen pesticide compounds. A follow-up investigation six months later found little had changed.

The root cause is structural. California is America’s agricultural heartland, and its conventional farms have applied heavy volumes of pesticides for decades. This leaves cannabis operations highly vulnerable to “pesticide drift”- winds carrying chemical residues from neighboring farms onto cannabis crops. The problem of pesticide drift is well-established in California and widely documented, including by official state agencies. As far back as 2019, the state officially confirmed that a cannabis harvest had been damaged by pesticide drift from a neighboring vineyard.

“There are certain times of the year I’m not going to get samples from certain regions, because those samples will be contaminated pesticides used in conventional agriculture. There’s no way to keep that out of the air. It’s not even a possibility.”- Jeff Gray, Owner at SC Labs, one the labs that partnered with the LA Times investigation.

Compounding the problem, cannabis is a powerful bio-accumulator that absorbs impurities and heavy metals from the soil. In fact, it is so effective at this that it was deployed to remediate the land around Chernobyl after the nuclear accident in Ukraine. In California, where now-banned pesticides were used extensively for decades, cannabis grown today may carry a legacy chemical burden from the soil itself, such as Chlordane - a pesticide that was banned in 1988 but has a long half-life.

Further, we believe that there may not be enough of a consistent supply of low-cost cannabis biomass and concentrates that is clean of pesticides and heavy metals for the eventual national US market, for medical cannabinoid products that may get medical reimbursement and for the very strict export market into Europe.

We think that the activation of LEEF’s Salisbury Canyon Ranch (SCR), a 1,900-acre property in remote northeastern Santa Barbara County in California is a key catalyst for LEEF. The immediate result is lowering LEEF’s own cost by up to 80% from purchasing biomass for $25 to $50 a pound and instead producing that biomass itself for $8 per pound. To show how much of a key catalyst this was, LEEF’s gross margins doubled upon turning on just 30% of SCR.

We project LEEF’s Adj EBITDA to grow from a small loss in 2025 to approximately $15M in 2027. On this alone and without interstate commerce or exports, we believe LEEF could be worth close to $0.40 per share, which could lead to our investment increasing by 200%+ in the next 12-18 months.

But an even more exciting future awaits as the company builds a platform that can produce any cannabinoid input at a cost, quality and scale that is unmatched in cannabis. The company at scale should one day be able to produce over 70 million grams of distillate. That’s enough to supply 60% of California’s vape market at a price no one else can match.

Consider that in California, LEEF is selling distillate for $1 a gram. That same gram sells for $4 in New York, $6 in Massachusetts and $8 in New Jersey.

Our analysis leads us to the believe that with the opportunity of interstate commerce or the ability to export, this microcap company has the chance to be worth more than $1 billion, versus its sub-$100 million enterprise value. In a scenario where the company could supply products to more lucrative national or overseas markets, it is possible that our investment has the potential to increase by more than ten times.

We are about to close a special purpose vehicle that is investing in the company’s equity that includes lucrative warrants. If you have interest, please let me know.

Grown Rogue Is Only Producing at 42% of Capacity

Grown Rogue (OTC: GRUSF) is licensed across five states - Oregon, Michigan, New Jersey, Illinois, and Minnesota - but today it is using only 42% of its total production capacity. Two of those five states haven’t produced a single pound of flower. A third state is at half its capacity. The company has been spending ahead of these opportunities and has yet to see the returns.

The business investors see today is a half-built machine. The question isn’t “what does Grown Rogue earn?” It’s “what does Grown Rogue earn when the lights are on in every room?”

Even at reasonably conservative prices, and an increase in current operating expenses, the company’s economics are very attractive and are the reason the company is now guiding to returns on incremental invested capital of 75%.

It has been painfully hard to be patient as Grown Rogue has retraced its big advance and has been under constant selling pressure from funds shutting down and few willing to do any work on the underlying unit level economics. All the while, Oregon and Michigan experienced a brutal price decline and New Jersey took longer than expected to fully activate.

But the wait is almost over. The final phase of the New Jersey facility is under construction, and the facility will soon be at full capacity. Illinois and Minnesota are in active development, with first harvests expected to start contributing to 2026 and ramp through 2027.

The company is turning the lights on a lot more cultivation capacity, and come this time next year, Grown Rogue should be a substantially larger and much more profitable company.

At today’s valuation, the market is pricing in what Grown Rogue earns at 42% utilization. It is not pricing in what the company earns when every cultivation room is running. That gap between $5M in EBITDA and $50M in EBITDA is the opportunity.

If you would like to play around with the assumptions made in this post, click on the link below and you can play around with cost and sales assumptions yourself. As always please do your own due diligence and rely on your research.

Grown Rogue Capacity Analysis Link

And one final note on Grown Rogue is that if there is ever interstate commerce, Grown Rogue should be one of the big beneficiaries. They are selling cannabis in Oregon for $600 a pound and in Michigan for $800, which would command much greater prices in other states. Also, they can grow a lot more outdoor cannabis in the Rogue Valley in Oregon, where conditions are perfect for growing outdoor cannabis. Not only is the full earnings power of Grown Rogue not being priced in, but the potential for interstate commerce is also not being priced in either.

Summary

Reform is the beginning of the game, not the end. We see a long runway of growth for our portfolio companies and think they are fundamentally mis-priced. Our companies are seeing accelerating growth, and the back half of this year should be very exciting.

With meaningful catalysts, strong expected growth, and improving earnings across our portfolio, we remain optimistic about both the near-term and long-term future.

As always, please reach out with any questions or comments.

Sincerely,

Aaron M. Edelheit

Today, acting Attorney General Todd Blanche and the Department of Justice rescheduled medical cannabis to Schedule III and booked a final hearing on rescheduling adult-use cannabis, beginning June 29th and ending July 15th. While the path forward has created some confusion, this is the first major federal cannabis reform in history.

Reform finally arrived — and yet again cannabis stocks fell. Why?

I remember being on a Zoom call at the peak of the cannabis hype cycle in 2021 with roughly 20 professional money managers, all talking about cannabis. Many have since shut down their funds and exited the space. Outside of my own investor base and one or two others, I know of no one actively deploying capital into cannabis right now — or planning to. Very few are doing any meaningful due diligence. Mindset Capital has over $50 million invested into the cannabis space and quite simply, there are very few institutional investors for me to share notes with anymore.

There is no wall of capital waiting at the gate, no large institutions locked and loaded to invest. There is no private equity of any size operating in cannabis. Existing investors are fully deployed and have been for years, most likely sitting on significant losses.

So, just as in December, we have good news — and yet most stocks fell.

And yet, I could not be more excited about investing in cannabis right now. To me, this rescheduling news is not the finish line where everyone suddenly gets rich, but the first pitch of the first game of the season.

What makes this news exciting is precisely the absence of institutional players and private equity: there is little or no competition to invest in the best companies with durable long-term advantages. And for the first time, we finally have profound regulatory change.

Here is another memory. In 2011, I stood on the courthouse steps in Atlanta, Georgia, bidding on foreclosed homes — stunned that there were no professional investors around. That all changed in the summer of 2012, when Colony and Blackstone showed up at the auctions. Prices and dynamics shifted immediately.

It won’t happen overnight, but capital will enter this space. The cannabis industry is too attractive and its potential too great for professional investors, private equity, and institutional capital to ignore.

I believe we have six to twelve months at most before we hear news of a major investor or a large strategic company entering the space — and it will shock people.

The game has begun. Do your due diligence, do your work. The advantages available right now may disappear when the big players arrive. There has never been a better time to do real research and invest in cannabis.

Want to read some other perspectives? Here are two great posts on rescheduling:

Marc Hauser’s Cannabis Musings

Cy Scott from Headset

With popular podcaster Joe Rogan standing behind him, the President made the following remarks at the 8-minute, 20-second mark:

“And you’re going to get the rescheduling done right, please?
Will you get the rescheduling done, please?
Do you know they’re slow-walking me on rescheduling?
Ok? You’re going to get it done, right?” -

“Absolutely.” - voice off camera responds to Trump.

This set off a rally in cannabis stocks, and I think the rally was not only justified but laid to rest any doubts that rescheduling is still on track.

To understand what the President is doing here, you need to understand the backdrop.

Axios reported that President Trump and his administration officials are working aggressively behind the scenes to court Joe Rogan, even as the podcast titan criticizes the president over the Iran war. Rogan’s backing, and his pull with young male listeners, helped power Trump to a second term — and the president knows that keeping him close still matters. According to a Trump aide, the White House had been working to build bridges to Rogan for months, with Trump “frequently” in touch with the podcaster. Within the White House, the executive order was seen as a way to maintain that bridge.

Joe Rogan is very passionate about cannabis reform. In my opinion, the President’s comments are a promise that while cannabis reform is moving slowly, it is going to happen.

As to the slow pace, my view is that rescheduling must be done correctly. Prohibitionists — led by opioid manufacturers and alcohol brands — have already signaled they plan to sue the administration, and have even sued the government to block a medical pilot of low-dose CBD products for seniors. If the process isn’t handled properly, any rescheduling risks being overturned in court.

But make no mistake: rescheduling is coming, and it should be significant. I continue to believe it will represent the first pitch of the first ballgame for investors.

For those interested, I remain bullish on three publicly traded investments. (Please note that these are illiquid stocks — do your own due diligence):

1. Grown Rogue (OTC: GRUSF) — Only 42% of its production capacity is currently online, and the stock may trade at less than 2x estimated cash flow once that capacity is fully utilized.

2. Vireo (OTC: VREOF) — A roll-up of distressed cannabis assets on a trajectory to become one of the world’s largest cannabis companies, currently trading at just 5x projected cash flow.

3. LEEF Brands (OTC: LEEEF) — The California leader in cannabis concentrates, currently activating its Salisbury Canyon Ranch facility. This would allow the company to supply not only California but the broader U.S. and global markets with pesticide-free concentrates once federal reform occurs — potentially delivering returns of more than 10x the current value of the business.

With midterm elections approaching, the President has promised Joe Rogan that reform is on the way. Cannabis investors, get ready — the game you've been waiting for is finally about to begin.

Investors looking at Grown Rogue (GRUSF) see the surface-level numbers and move on. $32M in revenue. $5.4M in Adjusted EBITDA.

In our opinion, that’s the wrong way to look at the company.

Grown Rogue is licensed across five states - Oregon, Michigan, New Jersey, Illinois, and Minnesota - but today it is using barely 42% of its total production capacity. Two of those five states haven’t produced a single pound of flower. A third state is still at half its capacity. The company has been spending ahead of these opportunities and have yet to see the returns.

The business investors see today is a half-built machine. The question isn’t “what does Grown Rogue earn?” It’s “what does Grown Rogue earn when the lights are on in every room?”

The Capacity Math

Here’s the state-by-state breakdown. Current production reflects FY 2025 actuals. Full capacity reflects licensed nameplate across all five facilities. Even at reasonably conservative prices, and an increase in current operating expenses, the company’s economics are very attractive and are the reason the company is now guiding to returns on incremental invested capital of 75%.

$107M in revenue. $65.4M in gross profit — a 61% gross margin. And $50.4M in adjusted EBITDA or $0.20 per share.

That is more than a 3X increase in revenue, and a 10X increase in adjusted EBITDA from where the company sits today.

And remember, the pricing assumptions should be conservative. Minnesota as a market is likely to be supply constrained for years, according to Vireo CEO Jon Mazarakis. A private operator recently said they expect to be “sold out for the foreseeable future.” The state of Minnesota itself estimates that an additional 1 million square feet of cultivation will be needed to satisfy demand. We believe that pricing is likely to remain high for several years.

But even if we got draconian and assumed tough pricing in all markets including Minnesota, this is what Grown Rogue looks like at full capacity, and as you can see the company is still quite profitable.

It has been painfully hard to be patient as Grown Rogue has retraced its big advance and has been under constant selling pressure from funds shutting down and few willing to do any work on the underlying unit level economics. All the while, Oregon and Michigan experienced a brutal price decline and New Jersey took longer than expected to fully activate.

But the wait is almost over. The final phase of the New Jersey facility is under construction and the facility will soon be at full capacity. Illinois and Minnesota are in active development, with first harvests expected to start contributing to 2026 and ramp through 2027.

The company is turning the lights on a lot more cultivation capacity and come this time next year; Grown Rogue should be a substantially larger and a much more profitable company.

At today’s valuation, the market is pricing in what Grown Rogue earns at 42% utilization. It is not pricing in what the company earns when every cultivation room is running. That gap between $5M in EBITDA and $50M in EBITDA is the opportunity.

P.S. If you would like to play around with the assumptions made in this post, click on the link below and you can play around with cost and sales assumptions yourself. As always please so your own due diligence and rely on your research.

Grown Rogue Capacity Analysis Link

About two years ago, I signed on as a research consultant for TOKE to try to resurrect it. At the time, TOKE had $8 million in assets and really needed to surpass $50 million to break even. Cambria also has a policy of charging no fees on ETFs below $50 million in assets — which meant that for the past year, I too was paid nothing as the research consultant.

For two years, Cambria gave it a go, losing money the entire time. At one point, we got the ETF above $22 million, but even then it was a struggle to attract assets at a time when no one wanted to invest in cannabis.

What surprised me most was learning how some of the remaining institutional investors use ETFs. When I asked whether they would consider investing in TOKE, their feedback caught me off guard. These investors used ETFs purely as trading vehicles — for quick long and short trades — and they actually wanted more volatility. One large investor told me they didn’t care about performance. Another said they had no interest in understanding the nuances of individual companies; they were in it for short-term trades.

My goal was to attract capital to an industry I believe in and to expand access for investors who cannot participate in my funds because they are not accredited or qualified investors. It didn’t work out, but I will continue to do my best for the industry and the companies I believe in.

I’m proud of what we accomplished over the past two years. Including dividends, TOKE fell about 10% during my tenure — compared to a 55% decline in MSOS, the behemoth of the space.

Thank you to Cambria’s Meb Faber and Jonathan Keetz for trusting me these past two years!

With over $60 million in assets, Mindset Capital continues forward with multiple private funds in the cannabis space. We remain bullish on the opportunity and believe that with a long-term horizon, investors can generate very attractive returns with best-in-class operators in a messy industry with a very bright future.

Only in cannabis can a company report 11.3% same-store sales growth, beat estimates by over 10%, lay out a roadmap to double revenue—and still get a collective shrug from investors. Well, at least from the few investors still paying attention.

This week, Vireo (OTC: VREOF) reported a phenomenal quarter: $105 million in revenue, up 25% on a pro forma basis. Most importantly, this growth came at a time when many cannabis companies are struggling to grow at all.

The company’s outperformance was evident even in mature markets. In Nevada, Vireo grew sales 12% while the overall market grew just 2%. In Missouri, it grew 7% versus 2% for the market.

This sends a strong signal: Vireo is not just a Minnesota story or a roll-up strategy. The company is demonstrating it can execute and grow in highly competitive markets post-acquisition.

Minnesota Drives a Strong Forward Outlook

Vireo is nearing completion of its new indoor facility in Minnesota, which will significantly increase supply. CEO Jon Mazarakis noted that the market is likely to remain supply-constrained for years.

Our channel checks support this view. One private operator recently said they expect to be “sold out for the foreseeable future.” Despite being months from completion, this cultivator has already received overwhelming demand from retailers—some even willing to put down deposits to secure product.

Acquisition Train Continues Full Steam Ahead

Vireo is in the process of closing four acquisitions that could add over $400 million in annual revenue, all at valuations well below 5x EBITDA.

Once completed, the company could reach $800–$900 million in revenue, making it one of the five largest cannabis companies globally. We anticipated this trajectory last year, but the speed of execution has exceeded even our expectations.

We also expect meaningful synergies—particularly in Colorado, where the company could approach $200 million in revenue from a single state. When asked about future acquisitions, CEO Mazarakis (“Maz” in the industry) said, “We will never be done in Colorado.” We suspect that mindset extends well beyond Colorado.

Contrast with Other MSOs

The contrast between Vireo and other Tier 1 MSOs (with the exception of Green Thumb) could not be more stark. While many competitors are reporting declining revenues, Vireo is delivering double-digit growth backed by a fortress balance sheet, including over $100 million in cash.

In 2026, Vireo is poised to be one of the few cannabis companies delivering meaningful revenue growth—alongside names like Grown Rogue and LEEF. In fact, if the company maintains its current acquisition pace, we believe it is on a trajectory to become the largest cannabis company in the world by revenue.

Yet the stock still trades at just 4–5x EBITDA. In our view, this disconnect reflects a lack of investor participation in the sector. With limited capital remaining in cannabis—and little new money entering without federal reform—companies like Vireo are being overlooked.

Consider this: if the largest cannabis-focused ETF, MSOS, was to rebalance based on Vireo’s growing scale, it could need to purchase anywhere from 200 to 400 million shares (The index has 0.5% of its assets in Vireo at the moment). Given the stock’s current liquidity, that level of buying is not feasible today. But looking ahead, as new capital enters the space, it is likely to concentrate in the largest and fastest-growing operators—which should include Vireo.

We remain excited by Vireo’s strategy and believe the stock is materially undervalued relative to its growth, scale, and execution.

We are still Vireo bullish.

When I first drove out to Salisbury Canyon Ranch (SCR), owned by LEEF Brands (OTC: LEEEF, CSE: LEEF), I couldn’t understand why anyone would try to grow cannabis in the middle of nowhere. My cell phone stopped working about half an hour before I reached the farm.

Salisbury Canyon Ranch is 1,900 acres of remote wilderness in northeastern Santa Barbara County. And I now believe it may be the most important cannabis farm in America.

The first thing that captured my attention was learning that LEEF began growing cannabis there last year for $8 per pound.

Let me repeat that: LEEF is growing cannabis at SCR for $8 per pound.

That is nearly 70% lower than the price the company has historically paid for biomass in the open market to supply its concentrate manufacturing business. The sheer scale of the farm (as seen in the video above) means that, at full capacity, LEEF could supply nearly 70% of the entire vape market in California.

But economics alone do not make SCR remarkable. What makes the farm truly unique is its isolation, which helps ensure the cannabis biomass and concentrates produced there are free from pesticides and heavy metals.

We believe there is a significant problem with pesticides—particularly pesticide drift—in California. Our research suggests that only about 10% to 20% of farms in the state can consistently grow high-quality biomass without exposure to heavy metals or pesticides. Frankly, we have been shocked by what we’ve discovered.

This issue matters because vaping is now outselling flower in California, and the next generation of consumers overwhelmingly prefers vapes. For a product that is first concentrated and then inhaled directly into the lungs, ensuring that the input material is free of pesticides is critical. It is both a moral imperative and, in the world’s most litigious country, a business necessity.

We believe LEEF is building something truly special: the ability to grow pesticide-free cannabis biomass at an extremely low cost and then manufacture it into more than 100 concentrated products—distillate, live resin, rosin, and more. On the other side of federal reform, we believe the platform they are building could have substantial strategic value to potential acquirers and generate outsized returns for investors.

How Is It Possible to Grow Cannabis for $8 per Pound?

To answer that question, you must understand that LEEF’s goal is not to grow flower. Instead, the company grows biomass that can be concentrated into vape oil, resins, rosin, diamonds, and more than 100 different forms of cannabis extracts for leading California brands such as Kiva, Heavy Hitters (Mammoth), Wyld, and others.

Traditional cannabis cultivation focuses on producing pretty flowers and big buds. This often requires expensive pots, specialized soil and equipment, and a small army of workers to maintain the plants, including bucking and trimming. It’s a labor-heavy, high-cost model.

Because LEEF grows the entire crop for extraction rather than flower, the company can eliminate much of that labor and many of those expenses. Instead of treating cannabis like a delicate specialty crop, they can grow it more like corn.

It also helps that the farm is located in one of the best places in the world to grow cannabis. The area receives more than 300 days of sunlight per year and enjoys nearly perfect weather conditions. The farm’s location in the high desert of New Cuyama also largely eliminates mold issues that are common closer to the coast and in other parts of California.

Finally, the soil is clean, and the farm’s remote location—surrounded by mountains and national forest—protects it from pesticide drift from neighboring farms.

Before acquiring and activating SCR, LEEF struggled with an inconsistent supply chain. One reason the company had difficulty was that it could not reliably source clean biomass. As a result, it was paying roughly $25 per pound on the open market. It also lacked the working capital necessary to source enough biomass and was actively turning away millions of dollars of sales every year.

Last year, LEEF activated roughly 30% of the farm, and almost immediately, its gross margins doubled in Q3 2025. By producing its own biomass for under $8 per pound, the company was able to replace material that previously cost about $25 per pound.

Even more remarkable—one of the reasons we spend so much time in and around cannabis—is that the stock has fallen by about 30% since these results were reported.

One of our favorite things to do at Mindset is to pour gasoline on a fire.

So, we are leading a round of up to $8 million in growth capital so that LEEF can activate the remainder of the farm, fully reduce its cost structure from $25 per pound to $8 per pound, and expand its New York operations.

We believe LEEF could produce $15–$20 million of EBITDA once the farm is fully operational, making it the premier producer of clean, low-cost cannabis inputs in California—and possibly the world.

But this raises an obvious question:

Why isn’t everyone doing this?

Why is this one farm so special?

And this leads to the most remarkable aspect of LEEF.

The main reason we are passionate about what the company is building is not simply the ability to reduce costs by nearly 70%—though that is certainly impressive.

The real reason is the problem of pesticide drift and why this farm is uniquely positioned to avoid it.

But before we talk about pesticides, we must start with Chernobyl.

Remediating Chernobyl with Hemp

In 1986, the world’s worst nuclear disaster occurred when explosions destroyed a reactor at the Chernobyl nuclear power plant in the Soviet Union. Fires burned for ten days, sending radioactive material across much of Europe.

Less widely known is that in the late 1990s, researchers began planting industrial hemp in the surrounding exclusion zone as part of efforts to remediate contaminated soil.

Why hemp?

Cannabis plants are powerful bio-accumulators. Some experts even refer to them as “hyper-accumulators,” although technically they do not meet the strict scientific definition.

In simple terms, cannabis plants absorb heavy metals from the soil. This is extremely useful if your goal is to clean contaminated land—such as the soil around Chernobyl.

But it is obviously not what you want if the plant is destined to be smoked, inhaled, or ingested.

This is why cannabis undergoes extensive testing for heavy metals. Many farms cannot plant directly in the ground and instead must grow cannabis in raised beds or containers. In some cases, contamination does not come from the soil but from groundwater, causing crops to fail testing even after the plants have grown successfully.

Heavy metals can sometimes be removed through processing.

The bigger problem is pesticides—especially pesticide drift.

Pesticides and Pesticide Drift Are Major Problems in California

California is the breadbasket of America. Regions such as the Central Valley and Salinas—where much of the state’s cannabis is cultivated—are dominated by industrial agriculture.

Strong winds regularly carry pesticides from neighboring crops onto cannabis farms, a phenomenon known as pesticide drift. In some cases, soils have also been contaminated by past pesticide use, and these contaminants can be absorbed by cannabis plants due to their bioaccumulating properties.

In flower products, trace amounts of pesticides may not trigger alarm. But when cannabis is concentrated into oils and extracts, those impurities are concentrated as well. A trace amount in the plant can become a dangerous dose when refined into a vape cartridge and inhaled directly into the lungs.

The extent of this problem became clear in 2024 when a Los Angeles Times investigation found that 60% of randomly sampled cannabis products contained pesticides exceeding safety limits, including known carcinogens. Some vape cartridges contained more than two dozen pesticides.

A follow-up investigation six months later found that little had changed despite public outcry.

SCR’s Unique Location

And this brings us back to Salisbury Canyon Ranch.

The farm is surrounded on three sides by national forest, and there are no neighboring farms nearby. Winds come in from the forest rather than from industrial agriculture.

A short hike from the property leads to Native American cave paintings—it is that remote.

The soil is clean. The air is clean. And the climate is nearly perfect.

This combination of isolation and ideal growing conditions makes SCR uniquely suited to produce clean cannabis biomass at scale.

The Strategic Value of LEEF

A quote from one of the Los Angeles Times investigations highlights the problem:

“The contamination is so widespread there is evidence of insufficient clean-grown weed to supply the state’s $1-billion cannabis vape market.”

One manufacturer reported that 60% of the cannabis crops offered to them contained pesticides not on California’s screening list, and they could only supply clean oil to a limited number of customers willing to pay higher prices.

Our channel checks confirm that building a supply chain that consistently produces clean, pesticide-free weed requires years of vetting partners, running endless expensive tests, and trial & error. It often lacks the scalability and agility that national brands in other industries take for granted.

With a consistent supply of clean biomass combined with the ability to manufacture virtually any type of cannabis extract at extremely low cost, we believe LEEF is building a platform with substantial strategic value.

There are numerous potential acquirers—both inside and outside the cannabis industry—that would want to control such a platform, especially once federal reform occurs.

Could LEEF Be a Billion-Dollar Company One Day?

The opportunity may extend beyond California.

Europe is gradually legalizing cannabis, and markets such as Germany and the UK are becoming increasingly attractive. However, regulatory and testing requirements are extremely strict.

One Portuguese company told us it is currently paying $180 per pound for clean biomass—largely because it must be grown indoors.

We believe SCR could produce 1.3 million pounds of biomass at $8 per pound, potentially increasing to 2 million pounds at $5 per pound over time.

Even assuming a modest $50 per pound export price, that would imply a business capable of generating roughly $90 million in EBITDA.

At a 12× multiple, LEEF could theoretically be worth more than $1 billion.

Optionality

LEEF has spent years building a strong reputation in California, supplying well-known brands such as Wyld, Kiva, and Heavy Hitters.

Now the company is following its customers.

After repeated requests from partners, LEEF expanded into New York last year and is exploring expansion into additional states.

The company also owns a CBD brand, LEEF Organics, which previously sold products through Nordstrom, Marriott, and other high-profile locations before the CBD market downturn.

After the CBD Medicare announcement, management is also exploring potential CBD opportunities in healthcare and possible partnerships, including discussions with NBA player Jimmy Butler, an investor in the company.

Leadership

Another exciting development is that seasoned executive and cannabis investor Jamie Mendola is joining the board and participating in the new funding round.

The company is led by Micah Anderson, whose commitment to organic agriculture dates to his early 20s when he actively protested GMO foods and pesticides. The purity of the company’s products is deeply embedded in its culture.

Summary

LEEF embodies the reason I love investing.

I enjoy discovering something I previously did not understand and finding a diamond in the rough during profound company and industry change.

We are proud that Mindset is helping turn over a new LEEF and excited to help the company build the cleanest, lowest-cost supply of cannabinoids in the world.

P.S. We are working on a much deeper report on LEEF that will be released in the coming weeks.

Stay tuned.

The Mindset Value Wellness Fund gained 20.5% on a net basis during Q4 and finished up 6.7% year-to-date.

A Hat Trick: Three Positive Years in a Row in Cannabis

Cannabis investing has been far more volatile than I ever imagined when I launched this fund. We stumbled out of the gate after launching in 2022, but I’m proud to report that 2025 marks our third consecutive year of positive returns—a veritable hat trick.

I’ve spent time in the past publicly owning my mistakes, so allow me—briefly—to give both myself and the Mindset team a well-earned pat on the back.

The Mindset Value Wellness Fund is up 200% since the beginning of 2023, an astonishing return when you consider that the primary cannabis index, the MSOS ETF, is down more than 32% over the same period.

We have long argued that cannabis offers tremendous alpha due to several structural inefficiencies:

· minimal institutional participation

· limited quality research

· a lack of focus on unit-level economics

· and an obsessive fixation by many investors on federal reform, often without regard to cost structure or long-term competitive advantage

These conditions have allowed us to focus intensely on companies with durable cost advantages and on compelling special situations.

Out of 27 publicly traded U.S. cannabis companies, only six have produced positive returns over the past three years. Our portfolio performance during this period has been driven primarily by three companies—which also happen to be the top three performers in the entire sector:

· #1 Glass House Brands (OTC: GLASF): 67.46% CAGR

· #2 Grown Rogue (OTC: GRUSF): 67.45% CAGR

· #3 Vireo (OTC: VREOF): 55.6% CAGR

The next-best publicly traded cannabis company generated a positive CAGR of just over 27%.

These results are the product of a true team effort, including Fateh Mann, our Senior Analyst, and Caroline Farrell, our Head of Operations and Administration. I’m extremely fortunate to work alongside both of them.

However, we are not resting on our laurels. On the contrary, we are actively pursuing our next investments and positioning the portfolio for the next three years. Our focus remains unwavering: cost control, operational excellence, and capital discipline.

Trump Moves to Reschedule Cannabis

Last quarter, I wrote:

“While patience has been necessary and the waiting frustrating, we believe there is now a strong likelihood of meaningful federal reform before the midterm elections next year.”

In December, President Trump signed an executive order directing Attorney General Pam Bondi to “take all necessary steps to complete the rulemaking process related to rescheduling marijuana to Schedule III of the Controlled Substances Act (CSA) in the most expeditious manner in accordance with federal law.”

In plain English: Trump instructed the Attorney General to move cannabis to Schedule III.

This was a historic moment in U.S. cannabis policy—arguably the first meaningful federal shift since cannabis was placed into the CSA as a Schedule I substance alongside drugs like heroin.

Without getting lost in procedural weeds, I now expect cannabis to be officially rescheduled sometime in the first half of this year.

Importantly, I view this announcement as the beginning, not the end, of the opportunity in cannabis. December’s news did not instantly make investors rich—because it isn’t the endgame. It is the first pitch, not the final inning.

I expanded on this idea in greater detail in a post titled The First Pitch.

Grown Rogue’s Cost Advantages Should Drive Strong Growth

One of the primary ways we have generated outsized returns in cannabis is by focusing on unit-level economics, particularly the cost to produce one pound of cannabis flower. From the outset, we have sought operators with genuine and sustainable cost advantages.

Our research revealed one of the great myths of cannabis investing: that cannabis is easy to grow.

This insight led us to become early investors in Glass House Brands and to “pound the table” in 2022 and 2023, when the stock price failed to reflect its cost advantages or the growth potential those advantages would unlock. Glass House could profitably grow cannabis when many competitors could not.

Since then, Glass House has significantly outperformed the broader cannabis sector and now trades at a healthy valuation multiple that reflects both its cost leadership and its growth runway as additional greenhouses come online.

While Glass House benefits from massive scale and state-of-the-art greenhouse cultivation, we believe Grown Rogue has developed a meaningful cost advantage in indoor craft flower. Our research indicates that Grown Rogue may operate at more than a 50% cost advantage relative to larger U.S. cannabis operators, who mainly grow indoors.

This advantage matters because it allows the company to operate profitably in markets where others cannot like in markets like Oregon and Michigan. Further, this allows the company to produce outsized returns when it enters markets like New Jersey with constrained supply.

In December, Grown Rogue announced it was sold out in New Jersey and had begun construction on Phase 2 of its indoor facility. The company has also started building a new facility in Minnesota—a market that is structurally short on cannabis flower and likely to remain so for some time.

However, there may be even more compelling opportunities not in traditional expansion through new licenses or greenfield builds, but instead with stepping into facilities abandoned by operators who could not compete or went bankrupt.

The cannabis industry is currently experiencing widespread distress driven by oversupply, falling prices, and capital scarcity. Based on our research, very few operators are capable—or willing—to take over these distressed assets and operate them profitably.

Grown Rogue has noted on recent conference calls that it is in discussions with cannabis lenders and cannabis real estate investors. Since the company operates at half the cost of peers, the opportunity to restart defunct facilities could represent a significant growth lever.

And what makes these opportunities especially attractive is the potential speed and capital efficiency. Instead of a two- to three-year buildout, these facilities could potentially be brought online in six to nine months with substantially lower capital expenditures. The incremental returns on invested capital could be materially higher for these distressed deals.

One of the major factors suppressing cannabis valuations has been the lack of visible growth pathways. Too many companies lack a clear plan for how incremental capital will generate attractive returns. Grown Rogue does not suffer from this problem.

We see a long runway for reinvestment and growth over the next three to five years, and it is our view that following a period of digestion and consolidation, both the company’s growth rate and stock price could inflect meaningfully this year.

New Opportunities Arise

We are currently working on new compelling transactions that may offer attractive yield along with substantial equity upside. We continue to be struck by the quality of asymmetric opportunities available in cannabis, largely due to the ongoing absence of venture and private equity capital.

These types of opportunities are increasingly rare in other sectors—and we believe they should continue to present themselves in cannabis.

More to come shortly.

Summary

In our view, reform marks the start of the game, not the end. We see a long runway of growth and a robust opportunity set ahead.

Our portfolio is likely to remain volatile in the near term, particularly given limited liquidity in publicly traded cannabis equities. However, just as the past three years have been rewarding, we believe the next three years could be even more compelling.

With meaningful catalysts, improving earnings, and strong growth prospects across the portfolio, we remain optimistic about both the near-term and long-term outlook.

As always, please don’t hesitate to reach out with questions or comments.

Sincerely,

Aaron M. Edelheit

The Mindset Value Fund gained 19.6% on a net basis in Q4 and finished up 4.8% year-to-date.

Consorcio Ara is a Value Trap No More

Consorcio Ara (BMV: ARA) is a Mexican home builder that has long been a classic value trap, but we believe new leadership is going to move aggressively to unlock its value.

Despite a pristine balance sheet, strong free cashflow, and a solid dividend, ARA has traded for years at a ludicrous valuation of 30% of its book value as the company has been under-earning their cost of capital. But change is afoot. A historic leadership transition has led to a shift in the company’s DNA- reorienting the company to maximizing Return on Equity just as the Mexican Government leads a massive national push to fix its acute housing shortage.

This combination of proactive management and strong industry tailwinds sets the stage for a dramatic revaluation of the company’s share price as revenue, earnings, return on equity and dividends all shoot higher.

This has been a long time holding for the fund and we believe 2026 could be the year that the stock breaks out to the upside in a dramatic way.

We wrote a new long form deep dive research report on Consorcio Ara that you can find at this link: Consorcio Ara Research Report.

HireQuest Buys Back Stock

In our second-quarter investor letter, we wrote about HireQuest (NASDAQ: HQI) and its efforts to acquire a poorly managed competitor, TrueBlue (NYSE: TBI). While there has been no update on a potential tie-up between the two companies, HireQuest’s stock sold off sharply in Q4, reaching a low of $7.38. This decline appeared driven by tax-loss selling and other non-fundamental factors.

We were aggressive buyers. HireQuest’s franchise model makes it a cash-generating business with minimal debt, a combination we find particularly attractive. Sure enough, on December 17, the company announced a $20 million share repurchase program—an amount that, at the time, represented most of the publicly traded float, as the company is tightly held by insiders. Since then, the stock has rebounded sharply and is now up roughly 50% from its lows.

The temporary staffing industry has been in a nearly three-year bear market for a variety of reasons, including the surge in illegal immigration from 2021 to 2024. We believe many of the forces that drove this weakness are now unwinding, and that headwinds are beginning to turn into tailwinds. We continue to believe HireQuest has a superior business model relative to much of the industry and that the stock offers significant upside, particularly if it can wrest control of TrueBlue.

We wrote a new long form deep dive research report on the company that you can find at this link: HireQuest Research Report.

Trump Moves to Reschedule Cannabis

Last quarter, I wrote:

“While patience has been necessary and the waiting frustrating, we believe there is now a strong likelihood of meaningful federal reform before the midterm elections next year.”

In December, President Trump signed an executive order directing Attorney General Pam Bondi to “take all necessary steps to complete the rulemaking process related to rescheduling marijuana to Schedule III of the Controlled Substances Act (CSA) in the most expeditious manner in accordance with federal law.”

In plain English: Trump instructed the Attorney General to move cannabis to Schedule III.

This was a historic moment in U.S. cannabis policy—arguably the first meaningful federal shift since cannabis was placed into the CSA as a Schedule I substance alongside drugs like heroin.

Without getting lost in procedural weeds, I now expect cannabis to be officially rescheduled sometime in the first half of this year.

Importantly, I view this announcement as the beginning, not the end, of the opportunity in cannabis. December’s news did not instantly make investors rich—because it isn’t the endgame. It is the first pitch, not the final inning.

I expanded on this idea in greater detail in a post titled The First Pitch.

Grown Rogue’s Cost Advantages Should Drive Strong Growth

One of the primary ways we have generated outsized returns in cannabis is by focusing on unit-level economics, particularly the cost to produce one pound of cannabis flower. From the outset, we have sought operators with genuine and sustainable cost advantages.

Our research revealed one of the great myths of cannabis investing: that cannabis is easy to grow.

This insight led us to become early investors in Glass House Brands and to “pound the table” in 2022 and 2023, when the stock price failed to reflect its cost advantages or the growth potential those advantages would unlock. Glass House could profitably grow cannabis when many competitors could not.

Since then, Glass House has significantly outperformed the broader cannabis sector and now trades at a healthy valuation multiple that reflects both its cost leadership and its growth runway as additional greenhouses come online.

While Glass House benefits from massive scale and state-of-the-art greenhouse cultivation, we believe Grown Rogue has developed a meaningful cost advantage in indoor craft flower. Our research indicates that Grown Rogue may operate at more than a 50% cost advantage relative to larger U.S. cannabis operators, who mainly grow indoors.

This advantage matters because it allows the company to operate profitably in markets where others cannot like in markets like Oregon and Michigan. Further, this allows the company to produce outsized returns when it enters markets like New Jersey with constrained supply.

In December, Grown Rogue announced it was sold out in New Jersey and had begun construction on Phase 2 of its indoor facility. The company has also started building a new facility in Minnesota—a market that is structurally short on cannabis flower and likely to remain so for some time.

However, there may be even more compelling opportunities not in traditional expansion through new licenses or greenfield builds, but instead with stepping into facilities abandoned by operators who could not compete or went bankrupt.

The cannabis industry is currently experiencing widespread distress driven by oversupply, falling prices, and capital scarcity. Based on our research, very few operators are capable—or willing—to take over these distressed assets and operate them profitably.

Grown Rogue has noted on recent conference calls that it is in discussions with cannabis lenders and cannabis real estate investors. Since the company operates at half the cost of peers, the opportunity to restart defunct facilities could represent a significant growth lever.

And what makes these opportunities especially attractive is the potential speed and capital efficiency. Instead of a two- to three-year buildout, these facilities could potentially be brought online in six to nine months with substantially lower capital expenditures. The incremental returns on invested capital could be materially higher for these distressed deals.

One of the major factors suppressing cannabis valuations has been the lack of visible growth pathways. Too many companies lack a clear plan for how incremental capital will generate attractive returns. Grown Rogue does not suffer from this problem.

We see a long runway for reinvestment and growth over the next three to five years, and it is our view that following a period of digestion and consolidation, both the company’s growth rate and stock price could inflect meaningfully this year.

Summary

Our portfolio has been exceptionally volatile the last few months. December for example was the second-best month we’ve ever posted. We expect this may continue up and down, but with meaningful catalysts, strong expected growth, and improving earnings across our portfolio, we remain optimistic about the long-term future of our portfolio.

As always, please reach out with any questions or comments.

Sincerely,

Aaron M. Edelheit

Last November, at the behest of Senator Mitch McConnell, the Senate slipped language into the bill reopening the government that effectively banned hemp and almost all CBD. That ban is set to go into effect in November of this year.

Since then, there has been growing recognition in Congress that this was a mistake—an overreach and an abuse of the way laws get passed. The White House’s December rescheduling announcement, which was shockingly pro-hemp, added fuel to the fire, especially after President Trump repeatedly praised the benefits of full-spectrum, hemp-derived CBD—products that would be banned under the language that was passed.

Now there is real momentum to delay implementation of the ban until 2028 so that, instead of a blanket ban, Congress has time to pass proper regulation of hemp. This would allow fully regulated, thriving hemp beverage markets—like Minnesota’s—to continue to prosper and would also give other states the freedom to decide how to treat hemp, just as they’ve decided how to regulate cannabis.

Over the past three days, I participated in a fly-in with the U.S. Hemp Roundtable and Hemp Industry and Farmers of America (HIFA) to lobby Congress for a hemp extension and to push for proper regulations. The participants included farmers who have already invested significant capital into land, equipment, and seeds for a hemp market that may no longer exist by November. It also included CEOs, producers, processors, and hemp beverage leaders.

I was there to tell the story of low-dose hemp beverages, and I was grateful to be joined by Theo Terris, CEO of Uncle Arnie’s; Adam Terry, CEO of Cantrip; Angus Rittenburg, CEO of Wynk; and several other CEOs.

We met with dozens of Members of Congress, along with their staff, Senate staffers, and lobbyists.

My primary mission was to educate everyone, but especially Representatives and their staff on who actually consumes hemp beverages. As the graphic I handed out shows, the primary consumer is a woman over the age of 35 who makes more than $75,000 per year. I’ve written before about the profound misunderstanding as to who consumes hemp. My goal was to educate.

The highlight of the week was the release of a bipartisan bill led by Representative Jim Baird and Representative Angie Craig called the Hemp Planting Predictability Act. The bill extends the deadline for the ban to November 2028. The following day, Representative James Comer hosted a press conference to highlight the proposed legislation.

I am an investor in both cannabis and hemp companies, and I believe there is a place for both. Blanket bans and “reefer madness” aren’t the answer. The answer is proper regulation—and expanding the distribution and availability of safe, tested, and regulated cannabinoid products.

There is now a real opportunity in Congress to take the time to regulate hemp the right way, and I believe that’s ultimately a win for everyone.

I believe in hemp beverages. I believe in cannabis. I left it all on the field in DC this past week to fight for what I believe in.

If you agree with me, I’m asking you to reach out to your Representative and urge them to include the hemp ban extension in the next continuing resolution—and to take the time to properly regulate hemp. Tell them you support Representative Jim Baird’s bill.

Here is an easy way for you to find out how to contact your representatives:

Find Your Representative Link

And here again is the link for the bill itself:

Hemp Planting Predictability Act Link

P.S. Here are some pictures below from my visit as well:

My House Representative Salud Carbajal and me:

Theo Terris, Angus Rittenburg and me in between meetings:

Theo Terris, me and Adam Terry in the Senate building after a meeting with staffers:

Representative James Comer discussing with me the prospects for the extension:

I’m also really grateful to those who took me on a private tour of the West Wing:

Several of America’s Founding Fathers were hemp farmers so you have to celebrate 250 years of America and hemp when you get the chance:

Last Thursday, President Donald Trump signed an Executive Order (EO) directing Attorney General Pam Bondi to “take all necessary steps to complete the rulemaking process related to rescheduling marijuana to Schedule III of the Controlled Substances Act (CSA) in the most expeditious manner in accordance with Federal law.”

In plain English: Trump is instructing the Attorney General to move cannabis to Schedule III.

This is a historic moment for U.S. cannabis policy—arguably the first meaningful federal shift since cannabis was placed into the CSA as a Schedule I substance, alongside drugs like heroin.

Without getting lost in the procedural weeds, I now expect cannabis to be officially rescheduled sometime in the first half of next year.

The question I’ve heard most from investors and friends is: What does this actually mean? And just as importantly: why have so many cannabis stocks dropped since the EO?

After a few days to think through what happened, here are my main takeaways:

1) The Executive Order (and ceremony) were surprisingly pro-hemp

I was shocked at how pro-hemp the executive order—and especially the messaging around it—seemed to be. I expected this to be mostly about regulated cannabis. Instead, much of the emphasis was on hemp and CBD.

To go from Mitch McConnell allegedly slipping hemp ban language into a government funding bill a month ago, to the White House speaking positively about hemp-derived products, is real whiplash.

2) “Full-spectrum” matters, and they leaned into it

President Trump, HHS Secretary RFK Jr., and Dr. Oz (as Administrator for the Centers for Medicare & Medicaid Services, CMS) repeatedly mentioned full-spectrum CBD—which is meaningfully different from CBD isolate.

Full-spectrum CBD includes multiple cannabinoids, terpenes, and small amounts of THC. Many believe this combination improves therapeutic effects via the “entourage effect.” In other words: full-spectrum products are often viewed as more effective than isolate.

One line from the written EO stood out:

“Adding complexity is the fact that some full-spectrum CBD products will once again be controlled as marijuana under the CSA when section 781 of Public Law 119-37 goes into effect because they contain THC levels above the per-container threshold set by that law.”

Translation: the White House is effectively signaling that the hemp ban language passed by Congress in November needs to be reworked, because it conflicts with what they say they want—particularly for full-spectrum CBD.

Even more importantly, under certain interpretations of the language, it may be impossible to produce CBD without producing THC as a byproduct.

Bottom line: I now think the White House may push Congress to delay, revise, or eliminate the hemp ban language—and replace it with proper regulation—because the current framework clashes with the policy direction they’re publicly endorsing.

3) Medicare reimbursement for full-spectrum CBD could be enormous

One of the biggest shocks wasn’t in the EO itself—it was Dr. Oz’s announcement. He said CMS will launch a pilot program in April in which Medicare and health insurers reimburse seniors up to $500 annually for full-spectrum CBD products for health and wellness. The stated goal is to expand the program broadly.

If this were expanded to all seniors, it would be massive—potentially larger than today’s U.S. cannabis industry.

4) Tax relief should help—but may be fleeting

Moving from Schedule I to Schedule III should provide relief from 280E, which currently prevents many normal business deductions.

That said, we’ve been skeptical about the long-term value of 280E relief. Over time, much of the benefit may get competed away and passed through to consumers.

We’ve seen versions of this before. When California eliminated its cultivation tax, the benefit didn’t sit with operators for long—prices fell, and consumers captured a large share of the savings. Rescheduling could accelerate price compression.

Yes, lower prices can expand the market and grow sales—but unit economics still matter. There are public cannabis companies with weak business models or structurally high expense structures that tax relief won’t fix.

Also note: many U.S. cannabis companies already aren’t paying meaningful 280E taxes (for various reasons), so rescheduling may not dramatically change their underlying economics.

We’ve previously discussed companies like Planet 13 (OTC: PLNH), which appears to have serious structural issues. A tax break doesn’t solve steep revenue declines or weak gross margins.

5) The “big” questions are still unknown

Key issues remain unresolved:

1. Can U.S. cannabis companies list on the NYSE or NASDAQ?

2. Will credit cards work at dispensaries?

3. Will federally regulated banks begin banking cannabis broadly?

4. What happens with interstate commerce?

5. Do institutional investors (e.g., major private equity) enter in size?

The honest answer: we don’t know yet.

6) Fast money arrived, didn’t get fireworks, and left

A lot of people were surprised that cannabis stocks sold off immediately after the announcement and kept sliding through Monday—nearly erasing the move that began when rumors started circulating.

In my view, this was “fast money” behavior. Many traders were positioned for an instant flood of capital and surging stock prices. When that didn’t materialize immediately, they exited about as quickly as they entered.

We remain firm in our belief that federal reform is the start of the game, not the end.

7) Where’s the growth?

Another headwind: many U.S. public cannabis companies are showing flat or negative growth, and very few look set up for meaningful growth in 2026. Many operate in limited-license markets where high prices are coming down. Meanwhile, the broader stock market is paying for growth—not excuses.

This is one reason I’ve been so focused on Minnesota. It’s one of the only newer adult-use markets with real runway, and its structure suggests it may remain short on flower production for a long time.

Minnesota likely needs roughly 1 million additional square feet of cultivation, requiring $300–$500 million of capex—and that’s not happening overnight or any time soon. In the near term, that dynamic benefits operators positioned to supply the market, including Green Thumb (OTC: GTBIF) and Vireo (OTC: VREOF), and eventually Grown Rogue (OTC: GRUSF).

Minnesota may end up separating the growers from the pretenders.

8) Exporting could become a meaningful opportunity

Ketamine is a Schedule III drug, and it is exported internationally from the U.S. More broadly, Schedule III substances can be exported if exporters follow DEA registration and export requirements (permits and/or export declarations depending on the substance).

We’ve already seen Canadian cannabis companies benefit from exports to Europe—improving pricing and helping absorb excess supply.

Could something similar happen with U.S. cannabis? Possibly. And if it does, low-cost, high-quality producers could be major beneficiaries—think operators like Glass House (OTC: GLASF) and Grown Rogue.

9) Mammoth: a clear beneficiary of the “health and wellness” shift

One of the biggest winners from last week’s messaging may be one of our largest investments: Mammoth Distribution, a house of brands that includes one of the strongest health-and-wellness brands in cannabis: Papa & Barkley.

Papa & Barkley was created by a son trying to help his senior-citizen father with cannabinoids. If the federal government truly starts pushing cannabinoid-based health and wellness—and especially if reimbursement becomes real—the long-term opportunity for that brand could be enormous.

I’m as bullish as I’ve ever been—and I continue to be amazed by how few long-term investors remain in cannabis. There’s still too much focus on getting rich quickly by trading headlines, and not enough focus on unit economics, operational execution, and long-term pricing dynamics.

That disconnect continues to create opportunities—especially in private companies positioned to win over the long term.

Gratitude to the activists

I also want to acknowledge the activists who fought for years to move cannabis reform forward. Among the people I know personally, I want to recognize Weldon Angelos for his work behind the scenes, and attorney Shane Pennington for pushing back against DEA efforts that could have derailed rescheduling.

Summary

I continue to believe the future is bright for cannabis, and last week’s announcement was a major milestone. It didn’t make everyone instantly rich—because it isn’t the endgame.

It’s the first pitch.

Let’s play ball.

But if you look at the stock chart, you might reasonably ask: why has the stock traded so poorly?

What went wrong is pretty simple: the New Jersey ramp was supposed to happen sooner. If there’s one thing I misjudged this year, it was the speed of that ramp. A year ago, I was fired up about the Garden State launch. Flower prices were over $3,000 per pound (versus roughly $600–$800 in Oregon and Michigan), and I assumed pricing like that meant the market was short on supply.

I didn’t fully appreciate how New Jersey is structured. A handful of large operators have outsized influence over pricing and supply dynamics. In practice, that meant the market could be “adequately supplied” even at high prices—and instead of selling through easily, Grown Rogue had to win accounts one dispensary at a time. But that wasn’t the only miss.

Another factor I underestimated: because of how Grown Rogue structured its New Jersey license—primarily as a loan—it couldn’t consolidate the results under IFRS. That created awkward reporting: investors had to rely on pro forma numbers, which turned off more than a few people.

And then, to add insult to injury, Oregon and Michigan saw a pricing downdraft.

So for much of 2025, instead of a clean ramp in growth and cash flow, the financials looked ugly: a slower-than-expected New Jersey ramp, funky accounting optics, and tougher conditions in two mature markets.

But the Grown Rogue story is as exciting as ever—if not more so.

In August, I wrote in The Future of Cannabis is Cost Advantage:

Cannabis cultivation is farming. And at its core, farming is about cost control—and constantly working to drive costs as low as possible.

What got obscured by the accounting weirdness and the difficult Oregon/Michigan environment is that Grown Rogue has made remarkable progress in lowering the cost to cultivate high-quality indoor flower. I first got excited about the company three years ago, when it was producing cannabis for about $600 per pound on a “four-wall operating” basis (all expenses, not just cost of goods sold). In Q3, Grown Rogue reported it had driven costs down to $348 per pound in Oregon—on par with California greenhouse economics.

In just three years, Grown Rogue has slashed its all-in cultivation costs by 42%.

And during this slower-than-expected year, the company also announced it won a license in Minnesota, secured a building under lease, and commenced construction.

As I’ve written before in Mighty Minnesota, the state likely needs at least 1 million additional square feet of cultivation capacity, which could require $300–$500 million of capex. Meanwhile, the rules cap the two existing players—Vireo (OTC: VREOF) and Green Thumb (OTC: GTBIF) —from expanding further, and new entrants can’t vertically integrate the way they can in other states. Combine limited vertical integration with an extreme shortage of capital, and I expect Minnesota to be flower-constrained for years.

One small cultivator currently building out its facility told me retailers were cold-calling to contract for supply—despite the first harvest being seven months away.

In short: with New Jersey ramping, Minnesota up next, Illinois after that, and the possibility of distressed opportunities across the industry, Grown Rogue has an exciting path to strong growth in 2026 and beyond. And in cannabis, growth is becoming a scarce asset—most companies are reporting flat or declining revenue.

It took a year longer than expected, but with growth ahead, strong unit-level economics, consolidated financials and the potential tailwind of rescheduling, Grown Rogue could light it up in 2026.

In reality, that couldn’t be further from the truth.

Cann is one of the largest low-dose beverage brands in the market. Its median consumer is 46 years old with an annual income of $75,000. 65% of their customers are women.

Cantrip’s typical consumer is also in their mid-40s, 55% female, and earns over $100,000 per year on average.

Soberish is 91% female, 93% of whom are 35 and up and the average income is $100k.

Happi is 80% female over the age of 35 and the median income is over $100k.

Cycling Frog’s core customers are women over 30, largely middle- to upper-class, often described as “soccer moms.”

Trail Magic’s customers have an average income above $150,000, with the largest segment aged 32–40, and the majority over 40. More than 35% earn over $200,000 annually — not exactly the “gas station” demographic.

On a personal note, I suffer from severe insomnia. These products help me sleep. Many people use them for sleep, pain, and anxiety, or simply as an alternative to alcohol, which can worsen sleep and depression.

Perhaps most importantly, these products are especially popular in red and purple states, where there are few or no alternatives for people who use them medicinally. Veterans in Texas were particularly vocal earlier this year when the state tried to ban hemp — and they made themselves heard.

If this federal hemp ban passes, it would mark the first time since Prohibition that the U.S. government has taken away products primarily used by middle- to upper-class Americans, the majority of whom are women. I’m not sure Congress realizes that, in their ignorance about who uses these products, they may be creating a wave of angry “Karens” right before the midterms.

One of the most prominent hemp brands, Cornbread, based in Kentucky, has an email list of more than 800,000. Cann has an email list of 360,000. Those two brands alone have over 1 million people on their email list. Imagine what will happen when they send out an email next year informing customers that, thanks to Congress, they can no longer receive their favorite products. Because so many policymakers misunderstand who these consumers are, they may not grasp just how explosive and politically damaging this issue could become.

With this proposed ban, Congress — and especially Republican leadership — risk alienating millions of voters, particularly women, right before a critical election. That doesn’t sound like a well-thought-out strategy.

If you believe in a safe, regulated market for hemp beverages, call 202-224-3121 and tell your Senator to remove the hemp ban language from the omnibus bill.