US SEC Trading Suspension Halt Orders — October 28, 2026

Nasdaq Hearings Panel denied continued listing on Oct 23, 2026; common stock and OSRHW warrants trade OTC after Nasdaq suspension since Aug 26, 2026

Management declined a reverse stock split to cure the bid-price deficiency, relying instead on organic initiatives, which lowers the odds of a near-term compliance-driven price reset

Reaffirmed $15M VXM01 equity put against BCM Europe AG, amended Oct 15, 2026 to permit convertible-note settlement at roughly $2.00–$5.00 per share, a potential source of liquidity or dilution depending on conversion terms

Received Nasdaq deficiency letter Oct 23, 2026 after 30 consecutive business days below $1.00; no present impact on listing status

Retains 180-day cure window to April 21, 2027, requiring at least 10 consecutive business days at or above $1.00, plus eligibility for a second compliance period

Nasdaq delisting determination for common stock and redeemable warrants (OSRHW) under Rule 5550(a)(2) for minimum bid price non-compliance, effective following Hearings Panel denial on Oct 23, 2026

Nasdaq trading suspended since Aug 26, 2026; securities now quoted OTC, typically reducing liquidity and institutional participation

$15M VXM01 put settlement via convertible notes at fixed prices of roughly $2.00–$5.00 per share could issue material share count relative to a sub-$1.00 trading price, depending on final terms

Evaluation of options has an undisclosed outcome with an update promised by Nov 6, 2026; absence of a defined path raises execution uncertainty

Intent to seek continuation of the Shareholder Loyalty CVR Program is not yet secured and may depend on listing outcome

Failure to cure may trigger transfer to Nasdaq Capital Market, requiring a $5,000 fee and possibly a reverse stock split

If cure is not achieved and transfer is not approved, a delisting notice follows, with appeal rights to a Nasdaq Hearings Panel only

180-day window through April 21, 2027 gives time for a sustained rally above $1.00 for 10 consecutive business days, which would clear the deficiency without a reverse split

Eligibility under Rule 5810(c)(3)(A)(ii) provides an additional runway if the first window is not met, reducing near-term forced-action risk

Company states it remains an SEC-reporting company and is evaluating options, so a defined restructuring or relisting path announced by Nov 6, 2026 could re-rate a severely discounted equity

The $15M BCM Europe put settled in convertible notes at $2.00–$5.00 could provide non-dilutive-at-current-price funding if the stock remains depressed, since conversion prices sit well above the sub-$1.00 market level

A successful push to continue the Shareholder Loyalty CVR Program could preserve value for holders and support sentiment during the OTC period

Both filings involve life sciences issuers falling below the Nasdaq $1.00 minimum, pointing to a recurring pattern where pipeline-stage biotechs exhaust cash and trade below listing thresholds; implication is elevated frequency of reverse splits, transfers, and delistings across the cohort

OSR chose to forgo a reverse split and contest through the Hearings Panel, while Milestone is still inside the cure period; the divergence shows that management choice, not just price, determines outcomes, so investors should weight governance decisions alongside market price

OSR's convertible-note settlement of a put option illustrates how distressed issuers use structured instruments to fund obligations, which increases dilution risk for common holders when stock prices are low

Nasdaq's staged process (deficiency letter, compliance period, transfer review, Hearings Panel, suspension) creates predictable decision points, enabling event-driven positioning around deadlines such as Nov 6, 2026 and Apr 21, 2027

Company update on evaluation of options promised by Nov 6, 2026; watch for restructuring, relisting, or wind-down announcements

Terms and timing of any VXM01 put settlement through convertible notes at $2.00–$5.00 per share, including share count implications

Outcome of request to continue the Shareholder Loyalty CVR Program

Share price performance versus $1.00 threshold; cure requires 10 consecutive business days at or above $1.00 before April 21, 2027

Any announced reverse stock split or transfer application to Nasdaq Capital Market, including $5,000 fee disclosure

Broader pattern of 5550(a)(2) and 5450(a)(1) actions against sub-$1.00 issuers in the current period, as a signal of exchange-level tightening