Appreciate the link.
Based on the way I've read it, 45 days is after the appointment of the technical reviewers, the reason why that's important is their appointment could take time. It's feasible to lodge the document could be two weeks for basic administration, then a further two weeks to appoint the TRs. Following appointment you've got 45 days of Due Diligence or 9 weeks as you've said.
So with that, yeah we could be very close, of course appointment could blow out, depends on the workload and availability of the TRs doing the DD itself, and there was a risk of US Govt Shutdown over that time period. I'd also potentially factor in delays with Aussie Post, just to avoid disappointment.
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