# Independent SEC/EDGAR Cross-Check — Late Public-Source Agent Return

**Doc ID:** AR-ADD-20260710-SEC-EDGAR-CROSSCHECK  
**Prepared:** July 10, 2026  
**Status:** Late-arriving public-source cross-check reviewed after the v3.6 candidate was created. This memo confirms what should be incorporated and identifies wording refinements.

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## 1. Overall disposition

The late public-source cross-check substantially agrees with the v3.6 candidate and does **not** require reversing the core ranking. It confirms that the strongest live issue remains the **Glass House Retail / NSJB / ASC 810 deconsolidation** lane, followed by DCC/local ownership-control approval records, DCC citation records, raid/labor agency files, and related-party governance.

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## 2. Confirmed points already captured in v3.6

1. **NYSE uplist:** Glass House announced NYSE approval on June 25, 2026, with GLAS trading expected to commence June 30, 2026. Commercial benefits such as interstate commerce or European expansion should be treated as forward-looking/open leads, not achieved facts.
2. **NSJB transaction architecture:** SEC exhibits verify NSJB's 100 Class A voting units / 10% economics and Glass House's retained 900 non-voting Exchangeable Units / 90% economics.
3. **ASC 810 status:** historical filings consolidated GHR; post-transaction ASC 810 conclusion remains open until the first post-closing financial statements, the ASC 810 memo, and any auditor concurrence are obtained.
4. **Auditor:** MGO remains the auditor reference point; audit committee/auditor records are the correct next request target.
5. **Beach Front / Rosenwald / Dalton:** official filings support related-party governance and entity-map questions, but not a current public-record finding that Dalton Investments itself is a current Glass House beneficial owner.
6. **Federal search warrants/raid exposure:** 2025 audited financials disclose July 10, 2025 search warrants and remote loss-contingency treatment. The agency files remain the proof source.

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## 3. Wording refinements to preserve

- Do **not** say the Protection Agreement simply “strips” Glass House of control. Better wording: the documents create a no-control/deconsolidation architecture while also preserving extensive protective, consent, reporting, access, and call/put rights that require ASC 810 analysis.
- Do **not** treat “deconsolidation narrative” as “verified non-VIE.” Verified fact is the transaction structure; the ASC 810/VIE/primary-beneficiary conclusion is an open company/auditor item.
- Do **not** treat Dalton Investments as a current Glass House beneficial owner unless a current official filing identifies Dalton itself. Current public materials reviewed point more directly to James B. Rosenwald III / Rosenwald family holdings and related entities.
- Management's “remote” loss-contingency disclosure for the July 2025 federal search warrants should be included as a disclosure fact, not as proof that the underlying agency matter is closed.

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## 4. Additional small items to carry into any next version

1. Add the June 19, 2026 AGM/voting-result press release as a source for MGO reappointment.
2. Add Glass House board biographies and early-warning releases as supporting source trails for Jocelyn Rosenwald / JBR III / Dalton / Beach Front mapping, while preserving the caveat that these do not themselves prove current Dalton corporate beneficial ownership.
3. Keep the “remote loss contingency” language from FY2025 audited financials in the disclosure-comparison section.

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## 5. Net effect on the ranked vulnerabilities

No rank change. The late cross-check strengthens, rather than weakens, the current order:

1. ASC 810 / NSJB / de facto control.
2. DCC/local ownership-control approvals.
3. NYSE-uplist disclosure completeness.
4. DCC citation packet.
5. Raid/labor/contractor agency files.
6. Related-party governance and Beach Front / RCM / Dalton / Jon A. Neu entity mapping.
7. Auditor-quality/audit-committee review.
8. Hemp/export compliance watch.