Max Zappia joined OCM from the Minnesota Department of Commerce, where he was Deputy Commissioner of Financial Institutions and oversaw the teams that worked on regulation of state-chartered banks, state-chartered credit unions, and non-depository (non-bank) financial institutions licensed in Minnesota, encompassing finance companies, mortgage-related businesses, and money transmitters. While at Commerce, Zappia worked on issues related to cannabis banking, including developing regulatory guidance for Minnesota financial institutions for hemp banking and interstate efforts to clarify federal cannabis banking regulations.