At least 19 social equity applicants in Delaware have had their conditional recreational marijuana licenses denied due to "predatory" consulting contracts. The Office of the Marijuana Commissioner (OMC) had to deny the 23 licenses to prevent the contracts from taking effect. The firm, Cannabis Business Advisors, was led by investor and entrepreneur Michael Halow and claims to have secured over three dozen cannabis licenses in 16 state application processes. The state social equity program helps disadvantaged Delawareans start their own cannabis businesses through discounted application and license fees. The fees charged by the consultant were excessive, leading to a potential for a controlling ownership interest in the license. Critics, including former president of the Delaware Cannabis Industry Association, James Brobyn, call it a scam.