CISO Global filed a no‑action request with the U.S. Securities and Exchange Commission on April 8, 2026, seeking clarity on an investor‑consent framework for securities lending. The request asks SEC staff to confirm that the proposed framework would not trigger enforcement under Rule 17Ad‑20, which restricts transfer agents from moving shares to intermediaries when restrictions exist.
The filing follows a review of short‑volume data, publicly reported fails‑to‑deliver transactions, and shareholder‑record discrepancies that raised concerns about how the company’s shares are being used in the market. CISO’s CEO David Jemmett said the initiative is “about one simple principle: informed consent.” He added that shareholders should have the right to know, decide, and say no before their shares are lent.
CISO Global, a provider of AI‑powered cybersecurity and compliance solutions, has seen its stock tumble 71% over the past six months, trading at $0.33 with a market capitalization of $15 million as of April 8, 2026. The company’s volatility underscores the importance of the proposed framework, which could protect shareholders from unintended exposure to short‑selling activity.
The request is supported pro bono by Nick Morgan, President of the Investor Choice Advocates Network, and securities attorney Mark Hiraide. Their involvement signals that the company is seeking a regulatory path that balances investor protection with market efficiency. The SEC’s response will be staff‑only and not a formal rulemaking, but it could set a precedent for other issuers.
While the SEC has not yet responded, the filing highlights CISO’s proactive stance on governance and shareholder rights. If the staff confirms the framework is permissible, the company could become a model for other issuers seeking to give shareholders a voice in securities lending practices.
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