# Schedule III / adult-use boundary / NYSE memo

## Issue

Glass House's NYSE uplisting was publicly tied to the reclassification of medical cannabis to Schedule III. The core suitability issue is whether the listed parent is meaningfully separated from non-medical/adult-use cannabis activity while retaining economics in Glass House Retail.

## Public facts

- Glass House announced NYSE approval on June 25, 2026 and expected GLAS trading beginning June 30, 2026.
- Glass House described the listing as not possible before recent medical cannabis Schedule III reclassification.
- Glass House Retail was separated/deconsolidated as the dual-use business, while the parent retained non-voting/non-participating exchangeable units.
- DEA materials distinguish medical marijuana Schedule III regulatory action from broader marijuana rescheduling proceedings.

## Diligence questions

1. What exactly did NYSE review regarding cannabis operations?
2. Did Glass House provide NYSE/SEC a legal memo on medical vs adult-use separation?
3. Does the listed parent retain adult-use economics or practical control through GHR agreements?
4. Are medical, adult-use, hemp, and export operations segregated in track-and-trace, accounting, inventory, personnel, and licenses?
5. Did public statements about interstate commerce/export go beyond existing legal authority?
6. Did any exchange, SEC, auditor, underwriter, or counsel raise comments about continued-listing suitability?

## Documents to request

- NYSE listing application and all cannabis-related correspondence.
- SEC comment/correspondence records, if any.
- Outside counsel memoranda on CSA/Schedule III, adult-use separation, and exchange suitability.
- Medical-only operational segregation policies.
- Adult-use deconsolidation operating protocol.
- Public statement review memos concerning interstate commerce, European export, and Schedule III.
