I agree with your assessment and timelines. However, the CHM letter is usually a precursor to denial, pending appeal? Someone here suggested that scenario. If that were the case, it would be a material event, do you agree?
"A CHM letter from the MHRA (Medicines and Healthcare products Regulatory Agency) in the UK is a formal notification that the Commission on Human Medicines (CHM) is advising against approval of a marketing authorization application for a medicine, potentially leading to denial. While not a direct denial, it signals a strong likelihood of refusal. "