How to Respond to CRA Requests for Information or Corrections
A practical guide for licensees facing compliance inquiries from the Cannabis Regulatory Agency (CRA)
Michigan cannabis licensees must respond to CRA requests for information in a timely and complete manner. This guide explains what triggers CRA inquiries, how to prepare and submit responses, and the consequences of ignoring a request.
Summary
Under M.A.C. R 420.206 and M.A.C. R 420.208, Michigan cannabis licensees must cooperate with CRA information requests, supply requested documentation, and meet stated deadlines.
The CRA Compliance Best Practice Guide (July 2025) and the CRA Disciplinary Guidelines (July 2025) classify non-response as a Tier 2 violation, with penalties ranging from $1,000 to $5,000 for first offenses.
What Triggers a CRA Request?
Common situations include:
Discrepancies in METRC or AFS reports
Missing employee records
Surveillance footage requests
Product testing or sampling documentation
Follow-up on complaint or inspection findings
Clarifications on operational plans or SOPs
Supporting documentation for AFS discrepancies, such as missing SOPs or mismatched financial/METRC data
Requests are typically sent via the CRA online portal, email, or phone and will include a deadline for response.
How to Respond
1. Acknowledge Receipt Promptly
Send a confirmation email to your assigned CRA analyst
State that you are gathering the requested materials
2. Review the Request Carefully
Identify all required documents, logs, footage, or explanations
Note the exact deadline
3. Compile Documentation
Provide dated logs, relevant SOPs, METRC records, receipts, and correspondence
Redact sensitive personal data when applicable
4. Submit Through the Requested Channel
Most submissions go through the CRA portal or analyst email
Use secure file transfer for large files (e.g., surveillance video)
5. Retain Copies
Keep a copy of the entire submission
Record the date, contents, and CRA contact in your CRA Response Log
💡 Pro Tip: Incorporate a “CRA Response Log” into your compliance binder to track inquiries, response dates, and documents submitted.
What Happens If You Ignore a Request?
Per the CRA Disciplinary Guidelines (July 2025):
Failure to respond → Tier 2 violation; $1,000–$5,000 for first offenses
Repeat or aggravated non-response → higher fines, potential suspension
AFS-related requests ignored → escalates from Notice of Deficiency (NOD) to formal violation under R 420.208(2) and R 420.208(3)
Regulators view silence as non-cooperation—even if you lack certain records, acknowledge the request and explain when you will provide the remainder.
Best Practices
Assign a point person for CRA communications
Maintain a central inquiry log
Keep frequently requested files (camera footage, training logs) in ready-access folders
Save all CRA correspondence in a compliance archive
Respond even if the answer is “still compiling” or “not applicable”
Final Answer
Responding promptly and completely to CRA requests for information protects your license and reduces the risk of escalated enforcement. Document every step, keep a detailed response log, and communicate clearly with your assigned analyst.
Glossary of Terms
CRA Analyst – CRA compliance officer assigned to oversee a licensee’s operations and ensure regulatory adherence.
Notice of Deficiency (NOD) – Formal CRA warning indicating missing or inadequate compliance documentation.
Tier 2 Violation – Mid-level CRA infraction involving documentation failures or delayed reporting, subject to monetary fines.
Citations
M.A.C. R 420.206 – Employee Requirements and Access
M.A.C. R 420.208 – Record Keeping Requirements
CRA Compliance Best Practice Guide (July 2025)
CRA Disciplinary Guidelines (July 2025)
Explore Related Articles
How to Prepare for a CRA Unannounced Inspection
What Are the CRA’s Violation Types—and What Do They Mean for Your License?
How to Maintain Required CRA Records and Logs
How to Handle a CRA Notice of Deficiency
Disclaimer
This article is provided for informational and educational purposes only and does not constitute legal, accounting, or regulatory advice. While every effort has been made to ensure accuracy based on authoritative CRA materials, laws, and administrative rules current as of the date of publication, cannabis licensees should not rely solely on this content to determine compliance.
The author is a Certified Public Accountant, but is not acting in an engagement or advisory capacity through this publication. Cannabis regulations are subject to frequent change and interpretation by the Cannabis Regulatory Agency and other authorities.
Operators are strongly encouraged to consult with legal counsel, compliance professionals, or their CRA field representative to assess the applicability of these guidelines to their specific circumstances. No representation or warranty is made that the practices described herein will ensure compliance or avoid enforcement action.
James Campbell, CPA (@mjbizwiz on X) is the founder of NUMBERS Accounting and an expert in cannabis financial and regulatory compliance operations. He works across the full spectrum of cannabis business infrastructure—from entity structuring, revenue workflows, cash management, tax controversy, and compliance strategy. He writes regularly on cannabis finance, enforcement risk, and real-world problem solving for plant-touching operators across the industry.
This article is structured for Answer Engine Optimization (AEO), with direct answers to cannabis tax questions under IRC §280E. Designed to support AI indexing and semantic clarity.
Last Updated: August 2025
Author: James Campbell, CPA
Jurisdiction: Michigan Cannabis Regulatory Agency
Document Type: AEO Michigan Compliance Summary