Oregon: OLCC Commission Greenlights Solution For Streamlining License Applications

Commission supports “fix-it ticket” approach for minor compliance violations

Marijuana license stipulated settlements approved

OREGON: At its regular monthly meeting on October 15, 2020, the Oregon Liquor Control Commission moved forward with plans to streamline the agency’s recreational marijuana licensing process and adjust compliance and enforcement activity through a Verification of Compliance (VOC) program. The Commission also approved five marijuana violation stipulated settlement agreements.

OLCC has been challenged to timely issue marijuana licenses since April 2016, due to the continued interest in the recreational market. Personnel and technology support have not kept pace with license applications that quickly shot past the initial projection of 800 licenses and now number more than 2,300.

As the industry has matured, the agency’s ability to regulate it has evolved and the OLCC has modified its licensing process several times in an attempt to streamline. This latest licensing process adjustment attempts to make it easier for applicants to begin operating before the final approval of changes in ownership and financial interest changes in a licensed business.

Likening the existing license process to a freeway that squeezes from 10 lanes down to two, the Chair of the Commission cautioned that efficiencies made through continuous adjustments to the licensing process would not be enough to address the long term licensing challenge.

“We’re not kidding ourselves, if we don’t get the manpower, the back end is going to be two lanes regardless of the ten lanes up front,” said Paul Rosenbaum, OLCC Chair. “If we don’t get the budget, we’re not going to solve this issue.”

For now, this licensing catch-up attempt will be similar to past efforts where staff were reallocated to the licensing division. Under this push to catchup, 16 OLCC staff members will be temporarily reassigned to licensing.

In addition to approving a temporary rule allowing the license process change, the Commission also initiated the permanent rulemaking process, which will expand the scope of the streamlining, as well as provide an opportunity for industry input.

The Commission also initiated the permanent rule making process for the new Verification of Compliance (VOC) program. The VOC program, which launched October 1, 2020, provides licensees with an opportunity to fix problems and avoid more severe penalties.

See Recreational Marijuana Program Compliance Education Bulletin 2020-05 for more information on the Verification of Compliance program.

The Commission also ratified the following violation fines and suspensions based on stipulated settlements (detailed information on specific cases can be found here on the OLCC website):

GREENRIDGE AGRONOMY will serve a 65-day recreational marijuana producer license suspension OR pay a fine of $5,775 AND serve a 30-day license suspension cfor six violations.

Licensee is: GreenRidge Agronomy, LLC; Stanley Tamiyasu, Member; Brandon Pierson, Member.

HEALING GREEN DISPENSARY in Independence will surrender its marijuana retailer license suspension for two violations.

Licensees are: Healing Green, LLC; Michael Hecht, Member.

KAYA FARMS (#A8DF) will surrender its recreational marijuana processor license suspension for two violations.

Licensees are: Sunstone Marketing Partners, LLC; Robert Frey, Member/Manager.

KAYA FARMS (#035C) will surrender its recreational marijuana producer license suspension for three violations.

Licensees are: Sunstone Marketing Partners, LLC; Robert Frey, Member/Manager.

UPMQUA GREEN CROSS in Roseburg will surrender its recreational marijuana retailer license suspension for seven violations.

Licensees are: Umpqua Green Cross, LLC; Edward Allen, Member.

OLCC Streamlining Marijuana License Applications

Temporary Rule Changes

OREGON:  On October 15, 2020, the Commission adopted temporary rules intended to provide relief to the industry and allowing OLCC greater flexibility in the processing of marijuana license applications. The main changes implemented in these temporary rules are:

  • Revising the definition of who needs to be identified as an “applicant” for the license, including raising the threshold from the 10% to 20% ownership.
  • Changing license application requirements, including reducing the amount of information and documentation which was previously required.
  • Modifying when OLCC may request fingerprints for a background check to once per license year, rather than specifically in conjunction with a renewal application.
  • Applicants can change the location of their proposed licensed premises prior to licensure, except for Producers who are prohibited by law from making that type of change until January 2022.
  • Changes to notification and pre-approval requirements when licensees make changes to business structures or financial interests (see below).
  • Simplified paperwork requirements for Producer propagation endorsement and medically designated canopy registration.

In the coming months, the Commission will go through a permanent rulemaking process to finalize the rules, making adjustments based on feedback from the industry and other stakeholders. Anyone wanting to provide comment or input on proposed rules should subscribe to OLCC’s email updates to stay apprised of the most recent activities, including dates and deadlines for public comment.

 

License Application Streamlining

In light of the current licensing backlog, Commission staff have been developing a comprehensive strategy to improve the processing time frame for all licensing actions. The agency believes that implementing the flexibility afforded by this temporary rule package and making internal process adjustments will significantly reduce the time it takes staff to evaluate each license application. The goal is to make the entire licensing process more efficient, timely, and predictable.

There are three main features that characterize the agency’s new streamlined approach to licensing:

  1. Collecting fewer documents as part of the license application.
  2. Relying on the applicant’s attestation that they have provided complete and accurate information.
  3. Giving the applicant the responsibility for knowing and understanding the laws and rules around marijuana licenses, and ensuring that their business will comply with those rules.

As part of the streamlining process, OLCC will ask applicants to complete updated paperwork which aligns with the temporary rule. We recognize that many applicants have already filled out and submitted paperwork for the license application, but the new set of paperwork is straightforward and will significantly reduce the time it takes OLCC staff to evaluate the license application.

Under the streamlined licensing process, a complete application will typically include:

  • An Application Packet for the appropriate license type. These forms have been streamlined to collect the minimum necessary amount of information. They also now include attestations that OLCC staff will rely on to be accurate when determining whether a license can be issued.
  • A Marijuana Applicant Questionnaire, along with an Individual History form for each individual who qualifies as an “applicant” for the license. The Applicant Questionnaire replaces all of the business structure forms that OLCC has historically collected. OLCC license investigators will no longer routinely collect detailed paperwork describing the structure and ownership of the business and analyze that information to determine which individuals and legal entities are “applicants.” Instead, it is the responsibility of the business to completely and accurately identify all “applicants.” The investigation process will not routinely consider other persons with a “financial interest,” although OLCC retains the authority to do so if necessary.
  • A map or sketch of the proposed premises and a floor plan for any indoor areas. New Premises Map Instructions are available that identify what information needs to be included on the map and floor plan. OLCC staff will rely on the applicant’s attestation that the map and floor plan(s) are complete and accurate.
  • A Land Use Compatibility Statement (LUCS). This requirement has not changed. An application must include this form, signed by the local government where the proposed premises is located, showing that the proposed license type is not a prohibited use at the proposed premises.

OLCC staff will continue to evaluate each applicant’s relevant criminal history and their record of compliance when previously licensed before issuing a license.

If an applicant has previously submitted fingerprints for a background check with another marijuana license application, OLCC staff will use the results of that license investigation rather than having the person submit new fingerprints. If an applicant has not previously submitted fingerprints, they will need to do so before the application is assigned to a license investigator.

OLCC will continue to contact applicants to confirm that they are prepared to complete the licensing process within 60 days before assigning them to a license investigator. As part of this contact, OLCC staff will provide instructions for applicants to submit fingerprints.  Do not submit fingerprints until you have received these instructions from OLCC staff.

The licensing timelines established in OAR 845-025-1135 still apply:

  • An applicant must complete the application process within 60 calendar days of being contacted by their license investigator.
    • If an applicant does not complete the process in 60 days and has not previously been in a “hold” status, the OLCC will un-assign the application and place it on hold until the Commission is able to reassign it; the reassignment will NOT take place until after other applications have been processed. Due to the volume of other license actions waiting to be processed, there could be a significant wait time before the OLCC reassigns the application.
    • If an applicant does not complete the process in 60 days and has previously been in a “hold” status, the application will be deemed incomplete and inactivated.

 

Blumenauer Calls On Supreme Court To Review Historic Appeal Challenging The Constitutionality Of Federal Criminalization Of Cannabis

DISTRICT OF COLUMBIA:  U.S. Rep. Earl Blumenauer (D-OR), founder and co-chair of the Congressional Cannabis Caucus, called upon the U.S. Supreme Court to review and proceed with hearing Washington v. Barr, the most significant and potentially consequential cannabis-related lawsuit ever to be filed.

The Court will consider the plaintiffs’ appeal at a conference on Friday, October 9, and if the Court accepts the appeal for consideration, it could pave the way to federal legalization of cannabis for the first time since 1937, providing relief to millions of Americans who treat with medical marijuana to maintain their health and lives. If the Court were to decline to hear the appeal, the case would be over for good, resigning another generation of medical marijuana patients and the state-legal cannabis industry – which has invested billions in the state-legal market – to further legal uncertainty.

“The fact that nearly 94 percent of Americans support legalizing medical cannabis and yet it remains illegal at the federal level is a national disgrace,” said Blumenauer. “Furthermore, the laws and subsequent court decisions on cannabis are a mangled patchwork of contradictions. This case is an important opportunity to fix our failed national cannabis laws.”

In July 2020, the plaintiffs in Washington v. Barr filed their appeal with the U.S. Supreme Court, challenging the constitutionality of the federal criminalization of medical marijuana. The case was filed on behalf of five plaintiffs, including former NFL player Marvin Washington, Iraq War Veteran Jose Belen, 15-year-old Alexis Bortell, nine-year-old Jagger Cotte and the Cannabis Cultural Association.

As acknowledged by the District Court in this case, Alexis, Jagger and Specialist Belen are patients whose lives have been saved by medical cannabis. As reflected in the Complaint, Marvin Washington is a cannabis entrepreneur whose business would otherwise be eligible for federal funding through the Minority Business Enterprise program, but for his participation in the cannabis industry. The Cannabis Cultural Association seeks economic parity and social justice for persons of color who have been unfairly singled out for prosecution under the Controlled Substances Act and unjustly excluded economically from the state-legal cannabis industry.

Blumenauer along with seven federal lawmakers submitted an amicus brief in support of the plaintiff’s appeal. The case also has amicus brief support from 19 advocacy groups, including the National Organization for the Reform of Marijuana Laws (NORML), the International Cannabis Bar Association, National Cannabis Industry Association (NCIA), Last Prisoner Project, Minority Cannabis Business Association, and Americans For Safe Access.

Despite its legalization by 38 U.S. states and territories, cannabis is illegal at the federal level, creating insurmountable problems for patients around the country. Patients have lost their jobs, been expelled from colleges, and lost their professional licenses, even if state-legal jurisdictions, due to cannabis stigmatization wrought by federal prohibition.

While cannabis is also on the ballot in five states that will be voting on some form of cannabis legalization in November, adoption of legalization electorally on the state level will not solve the problems associated with federal prohibition. Rather, it would merely reinforce the absurdity of marijuana’s classification under Schedule I.

To read the full amicus brief filed on behalf of Blumenauer and his Congressional colleagues, click here.

OLCC Suspends Marijuana Laboratory Licensee

Marijuana Products Tested At Unlicensed Location

OREGON: On September 21, 2020, the Oregon Liquor Control Commission (OLCC) issued an Order of Immediate License Suspension to the recreational marijuana lab licensee of Ecotest Labs in Phoenix, OR.  Ecotest Labs must not exercise any license privileges, or engage in any delivery or receipt of marijuana items, at the licensed premises, or any other premises until further order by the OLCC.

The immediate suspension was based on a series of violations which the OLCC used to determine that Ecotest’s continued operation represents a serious danger to the public health and safety. The licensee for Ecotest Labs is Proper Rental Management, LLC.

On July 23, 2020, the Oregon Environmental Laboratory Accreditation Program (ORELAP) informed the Commission it had suspended some of Ecotest’s testing accreditations for failing to meet required testing procedures and standards. ORELAP also suspected testing equipment had been relocated from the licensed premises in Phoenix, OR to an unlicensed location in Hillsboro, Oregon, where unregulated testing was taking place, and that testing results were being entered into METRC, the OLCC’s Cannabis Tracking System (CTS). In response, the OLCC launched an investigation.

The licensee told OLCC inspectors they had been experiencing problems with their accreditation, but had been recertified. The licensee also confirmed that since August 16, 2020, they had been transferring marijuana product to their unlicensed location in Hillsboro, while justifying incorrectly that ORELAP rules allowed for such transfers.

Upon further review of the licensee’s METRC accounts, OLCC discovered that Ecotest continued to conduct testing at this unlicensed, unaccredited Hillsboro location despite being informed by both OLCC and ORELAP that this activity was not permissible. At that point-in-time, the licensee had NOT submitted an application for a new location or for a change of location.

On September 2, 2020, OLCC expanded the investigation to include other state agencies: ORELAP, Oregon Health Authority and Oregon Department of Agriculture. Ecotest Lab – Immediate Suspension September 30, 2020.

On or about September 9, 2020, Ecotest’s licensed lab, located in Phoenix, was destroyed by the Almeda wildfire. Since then the licensee has not had a licensed premises where it could operate an OLCC approved lab, but had continued to test marijuana products through the unlicensed location in Hillsboro.

The licensee informed the Commission that it would be permanently moving its’ lab operations to the unlicensed Hillsboro location, and because the loss of the licensed location in Phoenix was caused by wildfire, it was not required to have OLCC approval, which is incorrect. OLCC staff then noticed that the licensee continued receiving marijuana samples and entering lab test information into its METRC account, which indicated that the licensee was continuing to operate at the unlicensed Hillsboro location.

The OLCC will be working to help recreational marijuana licensees impacted by wildfires, including expediting relocations according to required OLCC rules. However, some of the violations charged to Ecotest occurred before the licensee was impacted by wildfire, which impacts the business relocating and legally resuming testing of marijuana products.

Based on the initial investigation, the OLCC determined there was enough evidence to warrant the immediate suspension of Ecotest’s laboratory license. The OLCC investigation is continuing, and the licensee is entitled to exercise their administrative hearing rights to challenge the OLCC’s actions.

The OLCC has identified at least 160 affected licensees that received marijuana product tested for potency by Ecotest on or after August 21, 2020, and the agency will work with those licensees on a remedy to have the product re-tested. The OLCC has placed an administrative hold in CTS to prevent further distribution of product tested by Ecotest. Any potency tests conducted by Ecotest on or after August 21, 2020 will require retesting by an accredited, OLCC licensed laboratory for potency.

OLCC Seeks Input On Wildfire Impacts To Recreational Marijuana Licensees

OLCC Recreational Marijuana Licensee Wildfire Impact Survey

Survey designed to pinpoint problems, help create collaborative solutions

OREGON:  Wildfires around the state have had a devastating impact on Oregonians.  Authorities still don’t know how widespread the impact is. For evacuees and business owners who lived or worked in the fire zone there are plenty of challenges ahead.

If you’re an Oregon Liquor Control Commission Recreational Marijuana licensee impacted by the state’s wildfires please take 3 to 5 minutes to fill out this short survey.

Some recreational marijuana licensees have already notified the Oregon Liquor Control Commission that their businesses were destroyed by the fire. The OLCC is aware that there are many other licensees located in burn zones around the state. What OLCC doesn’t know is the extent of the damage to those licensed recreational marijuana businesses.

The OLCC wants to be able to help and advise licensees while ensuring that marijuana product remains secure, and accounted for in Oregon’s Cannabis Tracking System.

Licensees directly impacted by wildfire

That’s where we need help from our licensees. If you’re a licensee impacted by the fires please take a few minutes to fill out this short survey. If you know of an impacted licensee please let them know about the survey, and if need be help fill out the survey on their behalf.

Licensees not directly impacted by wildfire

If you have questions related to OLCC’s wildfire response, or have suggestions on how to address the regulatory situation and complexities caused by the wildfires please direct your questions by email to: marijuana@oregon.gov  Use the keywords “Wildfire Response” to start the subject line title.

Wildfire response by OLCC

The agency is working on an approach to address regulatory issues so we can accommodate licensees and help them maintain their operations.

The agency is also considering ways to best utilize our licensing staff to assist wildfire impacted licensees, while still maintaining our commitment to improve licensing processing for new applicants and licensees seeking renewals.

We’ll use the findings of the survey to directly inform temporary rules and licensing actions to help licensed businesses maintain operations to the greatest extent we are able. The more information you are willing and able to provide, the better able we will be to be responsive to the needs of our licensees.

Direct link to the OLCC Recreational Marijuana Licensee Wildfire Impact Survey:

https://www.surveymonkey.com/r/296WQD5

OREGON: OLCC Commission Approves Permanent Rules for Curbside Delivery

Continues social distancing approach to prevent spread of Covid-19

OMMP cardholder daily purchase increased

Marijuana license stipulated settlements approved

OREGON:

At its regular monthly meeting on September 11, 2020, the Oregon Liquor Control Commission approved permanent rules allowing licensed recreational marijuana retailers to continue curbside delivery transactions, and increased the marijuana flower purchase amount for OMMP cardholders and caregivers. The Commission also approved ten marijuana violation stipulated settlement agreements.

Shortly after the COVID-19 pandemic started, the OLCC approved temporary rules designed to prevent the spread of the COVID-19 virus. The change encouraged social distancing by allowing licensed marijuana retailers to conduct limited transactions outside but close to their physical location. Under the permanent rule licensed retailers can continue to take orders and deliver product to a person outside the store and within 150 feet of the retailer’s licensed premises.

The Commission believes this has proven to be an effective approach to limiting interactions and exposure to COVID. Although this rule is being made permanent due to the pandemic, commission staff will revisit this rule at a later date.

Commissioners also approved continuing the daily purchase limits for OMMP cardholders and caregivers that were approved in temporary rule on March 22, 2020. OMMP cardholders and caregivers will continue to be able to purchase up to 24 ounces per day and no more than 32 ounces per month.

The permanent rules take effect September 18, 2020.

The Commission also ratified the following violation fines and suspensions based on stipulated settlements (detailed information on specific cases can be found here on the OLCC website):

Green Valley Wellness in Talent will pay a fine of $4,950 OR serve a 30-day recreational marijuana retailer license suspension for one violation.

Licensee is: Green Valley Wellness, LLC; P&M Holdings, LLC; Peter Gross, Member; Michael Monarch, Member.

Ahanu Yates; permitee will serve a 30-day marijuana worker permit suspension or pay a $750 fine.

Crystal O’Connell; permitee will serve a 30-day marijuana worker permit suspension or pay a $750 fine.

Juliet King; permitee will serve a 30-day marijuana worker permit suspension or pay a $750 fine.

Tyler Kinert; permitee will serve a 30-day marijuana worker permit suspension or pay a $750 fine.

Heiple L3 will pay a fine of $1,155 OR serve a seven-day recreational marijuana producer license suspension for one violation.

Licensees are: Heiple L3, LLC; William Ng, Member.

Yachats Cannabis Company in Yachats will pay a fine of $1,155 OR serve a 7-day recreational marijuana retailer license suspension for one violation.

Licensees are: Yachats Cannabis Company, LLC; Aaron Bishop, Member; Kati Bishop, Member.

Dark Star Productions will pay a fine of $8,085 OR serve a 49-day recreational marijuana wholesaler license suspension for three violations.

Licensees are: Dark Star Productions, LLC; Kinyon Case, Member; Michelle Case, Member; Diania Turner, Member; Kacie Hersh, Member.

Lucky Lion/Dutch Alchemy in Eugene will pay a fine of $4,950 AND serve a two-day recreational marijuana retailer license suspension, OR serve a 32-day recreational marijuana retailer license suspension for one violation.

Licensees are: Dutch Alchemy, LLC; Hilltop Consulting, Inc., Member; Jake Hill, President, Director, Stockholder; Jacqueline Hill, Secretary, Treasurer, Stockholder.

Greenhill Cannabis Farms will surrender its recreational marijuana producer licenseAND each licensee agrees to accept a letter of reprimand for six violations.

Licensees are: Greenhill Cannabis Farms, LLC; Joshua McNamara, Member.

OLCC Compliance Education Bulletin: Medical Sales To A Designated Caregiver

OREGON: The OLCC has added a “Bulletins” section to its Recreational Marijuana Program website with important information for licensees and marijuana worker permit holders.

The Oregon Liquor Control Commission is providing the following information to: recreational marijuana licensees.

The bulletin is part of OLCC’s compliance education. It is important that you read it, and understand it.If you don’t understand it please contact the OLCC for help.

Failure to understand and follow the information contained in this bulletin could result in an OLCC rules compliance violation affecting your ability to work or operate your business.

A bulletin previously issued by Metrc inadvertently provided the incorrect date for when the CTS functionality change takes place.  The change in Metrc is effective starting September 14, 2020.

Bulletin CE2020-04 covers the following issues:

  • Medical Sales to a Caregiver
  • Sales Limits to Caregivers and Patients
  • New Metrc Functionality – Designating Caregiver Sales

Compliance Education Bulletin CE2020-04 provides updated guidance on medical sales to a Designated Caregiver, sales limits caregivers and patients, and changes in Metrc functionality for caregiver sales.

Medical Sales to a Designated Caregiver

The Oregon Medical Marijuana Program (OMMP) provides for patients to designate a caregiver who can purchase and possess marijuana items for the patient. The caregiver’s card references both the caregiver’s and patient’s registration number.

Effective September 14, 2020 new functionality in the Cannabis Tracking System (CTS), Metrc, now allows retailers to designate sales as “caregiver” sales, in addition to consumer and patient. When a caregiver sales is recorded, either manually in Metrc or through API or CSV upload, the retailer must input both the patient and caregiver numbers.

Rules allow for a patient and their caregiver to jointly possess up to 24 ounces of usable marijuana. This is to say, a retailer may sell up to the daily limit under both the patient’s and caregiver’s cards under the caregiver sales. This will go into effect when the daily sales limit returns to 8 ounces on September 18, 2020.

The bulletin describes the new functionality in Metrc and provides a step by step guide to entering a caregiver sales manually in the system. Metrc has previously provided API partners with details on this addition, so they should be ready to use this functionality in their systems.

Questions regarding the contents of this bulletin may be sent to marijuana.cts@oregon.gov.

Oregon: OLCC Commission Approves Marijuana Licensee Stipulated Settlements

OREGON: At its regular monthly meeting on August 20, 2020, the Oregon Liquor Control Commission approved six marijuana violation stipulated settlement agreements. The Commission also ratified the following violation fines and suspensions based on stipulated settlements (detailed information on specific cases can be found here on the OLCC website):

  • KALEAFA GRESHAM in Gresham will pay a fine of $7,000 for one violation, consolidating multiple packaging and labeling violations, against its recreational marijuana retailer license.

Licensee is: 1450 SE Orient, LLC; Chris Ostlund, Member; WWMP, LLC, Member; 3 Kids, Inc., Member; John Widmer, President/Stockholder; Julie Widmer, Secretary/Stockholder; Visionary Enterprises, Inc., Member; Rod Maguire, President/Stockholder; Melissa Maguire, Secretary/Stockholder.

KALEAFA will pay a fine of $28,000 for one violation, consolidating multiple packaging and labeling violations, against its recreational marijuana wholesaler license.

Licensees are: WWMP, LLC; 3 Kids, Inc., Member; John Widmer, President/Stockholder; Julie Widmer, Secretary/Stockholder; Visionary Enterprises, Inc., Member; Rod Maguire, President/Stockholder; Melissa Maguire, Secretary/Stockholder.

  • CANNA FLOW FARMS will pay a fine of $6,435 OR serve a 39-day recreational marijuana producer license suspension for two violations.

Licensees are: CannaFlo Farms, LLC; Jeffrey Schlageter, Member.

  • IVY CANNABIS will pay a fine of $4,125 OR serve a 25-day recreational marijuana wholesaler license suspension for three violations.

Licensees are: Attikus Enterprises, Inc.; Matthew Schwimmer, President/Stockholder; David Schwimmer, Vice President/Secretary/Stockholder.

  • MODERN FOREST in Lebanon will pay a fine of $14,025 OR serve an 85-day recreational marijuana retailer license suspension for two violations.

Licensee is: Modern Forest, LLC; Charles Troxell, Member; Laura Troxell, Member; Sven Roberts, Member; Amber Roberts, Member.

  • BUTTE CREEK FARMS will pay a fine of $14,850 OR serve a 90-day recreational marijuana producer license suspension for four violations.

Licensees are: Butte Creek Ranch Farm 1100, LLC; Thor Thompson, Member; Deborah Gadberry, Member; Tyler Lennick, Member.

OLCC Rules Advisory Committee Meetings Added Substances in Marijuana Rules Package AUDIO

OREGON:  The OLCC has released the audio from the July 29, 2020 Licensee and Industry RAC. The topic of the advisory meeting was draft rules concerning additives and added substances in the states legal marijuana products.

Listen to the audio here:

 

OLCC Marijuana Advisory Committee Meeting Is Thursday July 9, 2020

OREGON: The next OLCC Marijuana Advisory Committee Meeting will take place Thursday, July 9, 2020

Due to the outbreak of COVID-19, we are holding our meetings virtually. An audio recording of the meeting will be posted on our website.

You can listen live using your phone: 1 (872) 240-3311 Access Code: 786-241-877