From: James Campbell Sent: Friday, April 18, 2025 12:12 PM To: Joint Committee on Administrative Rules Subject: Public Comment on CRA Proposed Rule Set 2023-25 LR – Request for Legislative Review Attachments: Public Comment on Rule Set 2023-25 LR – Physical Inventory Audit Requirement.pdf I am writing to submit a formal public comment regarding the Michigan Cannabis Regulatory Agency’s proposed Rule Set 2023-25 LR, specifically the new requirement for biannual physical inventory audits by all licensees. As a Certified Public Accountant working directly with Michigan’s licensed cannabis businesses, I have serious concerns that this proposed rule may be an attempt to shift the burden of oversight onto licensees, rather than addressing possible internal data utilization failures within the state’s seed-to- sale tracking system (Metrc). My attached comment outlines these concerns in detail and draws from recent whistleblower litigation and national regulatory trends that mirror the challenges we now face in Michigan. Because public comments may be paraphrased or summarized in the CRA’s reporting process, I respectfully request that my comment be reviewed in full by your committee as you consider the broader implications of this rulemaking and the CRA’s enforcement practices. Thank you for your attention and your ongoing service to the citizens and businesses of Michigan. James Campbell CPA james@numbers.tax (248) 794-0798 James Campbell LLC is a Michigan Limited Liability Company, d/b/a NUMBERS Accounting, 2021, All Rights Reserved.