The Market has to complete the process....by issuing a Cusip #. If not.
The only way I see things working is a split of share structures and then some merger's with SS that have a Cusip.
I think he could push the issue. I don't think the market could stop a split and then merger.
Personally I think the Dodd/Frank clock started ticking in July of 2019. When Ally released divvy's @ .17 with regulatory waiver's. I believe that is a 2 year wavier on price. It might have been less.
BANK though I believe would have to be a NASDAQ filing. Hudson set aside 100,000,000 ENTI with the SEC.