TPI Portal Guide
What This Covers
How to use the OCM True Party of Interest (TPI) Portal for NY cannabis licenses.
The TPI Portal is the system the New York State Office of Cannabis Management (OCM) uses to collect, verify, and approve all True Party of Interest disclosures. An application cannot move forward until every required TPI completes the portal.
This page explains who must use the portal, what information is required, how OCM evaluates submissions, common errors, and how to update information.
Who Must Use the TPI Portal
All of the following must complete TPI disclosures:
- Individual TPIs
- Entity TPIs
- Applicants
- Licensees with ownership, management, or financial changes
Direct and indirect interests must be disclosed, including ownership, control, revenue rights, contract-based influence, and qualifying Goods & Services providers.
What the Portal Collects
The portal gathers comprehensive information about:
- Identification and contact details
- Ownership percentages and structures
- Financial rights, revenue share, and compensation
- Loans, promissory notes, and repayment terms
- Goods & Services agreements
- Officers, managers, and decision-makers
- Household relationships tied to financial influence
- Parent entities and chains of ownership
- Supporting documents for financial or management rights
All applicants must certify that all submitted information is accurate and complete.
Individual TPI Requirements
Individuals must disclose:
- Legal name and identifying information
- Contact information and residence history
- Employment history
- Ownership percentage or influence description
- Rights to revenue, profit, repayment, or compensation
- Management agreements or operational authority
- Goods & Services agreements
- Cannabis interests in other states
- Any control, influence, or ability to restrict business activities
OCM uses this information to determine TPI status, license control, and financial thresholds.
Entity TPI Requirements
Entities must disclose:
- Legal name, structure, and EIN
- Formation documents (operating agreement, bylaws, articles)
- Certificates of Good Standing
- Ownership charts and full organizational structure
- Officers, directors, and controlling individuals
- All persons behind the entity (look-through disclosure)
- Contracts, loans, and financial arrangements
- Related or parent companies
- Compensation and revenue rights
Every individual with ownership or control must be accounted for in entity disclosures.
Applicant Responsibilities
Applicants must:
- List every TPI (individual and entity)
- Upload ownership charts and organizational documents
- Provide all agreements tied to ownership, revenue, or control
- Ensure portal filings match the license application
- Certify no undisclosed individuals or entities exert influence
OCM compares applications to portal entries; mismatches can cause deficiency notices or denials.
How OCM Evaluates Submissions
OCM reviews TPI disclosures to check:
- Direct or indirect control
- Compensation exceeding the 10/50/250 rule
- Financial or controlling interest via Goods & Services contracts
- Compliance with vertical and horizontal ownership rules
- Full disclosure of individuals behind entities
- Document consistency across all TPIs
Common deficiency reasons include missing documents, inconsistent information, or incomplete ownership chains.
Updating TPI Information
Licensees must update the portal when:
- Ownership changes
- New contracts affect control or compensation
- New TPIs join
- Financial arrangements change
- Management roles or authority shift
- TPI legal names or addresses change
- A TPI leaves the business
OCM provides Interim TPI Change Request Guidance for processing temporary changes. Failure to update TPI information is a compliance violation.
Common Portal Issues
Frequent issues reported by OCM include:
- Listing TPIs in the application but not the portal
- Misclassifying Goods & Services providers as exempt
- Omitting passive investors above thresholds
- Leaving out individuals behind entity TPIs
- Unreported revenue rights or profit participation
- Missing or redacted contracts
- Conflicting information across TPIs
- Omitting household members sharing financial interests
Most issues are resolved by uploading complete documents and correcting inconsistencies.
Key Terms
True Party of Interest (TPI): Person or entity with ownership, control, influence, or financial interest
Direct or Indirect Financial or Controlling Interest (DIFCI): Person whose financial rights or influence meet OCM thresholds
Passive Investor (PI): Financial interest but no operational control
10/50/250 Rule: TPI status triggers if annual compensation exceeds 10% of gross revenue, 50% of net profits, or $250,000
Related Pages
Source Material
- OCM TPI Hub
- TPI Portal FAQ
- Retailer TPI FAQ
- Supply TPI FAQ
- Interim TPI Change Request Guidance
