CISO Global files no-action request for investor-consent framework
14 April 2026 US
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CISO Global, an Arizona-based AI-powered cybersecurity software provider, has filed a no-action request with the US 网爆吃瓜 and Exchange Commission (SEC) seeking regulatory clarity for a proposed investor-consent share loan programme.
The programme is designed to give shareholders a direct voice in whether their shares may be made available for securities lending.
The filing follows the firm鈥檚 review of short-volume data, publicly reported fails-to-deliver during late 2025, and shareholder-record discrepancies that the company believes warrant greater transparency and investor choice.
CISO notes that short sale volume data and fails-to-deliver data have important interpretive limitations as described by the Financial Industry Regulatory Authority (FINRA) and the SEC, and their presence does not by itself establish abusive or unlawful activity.
The firm is not alleging in its no-action request that any specific intermediary or market participant engaged in unlawful conduct.
According to CISO, beneficial owners should have a meaningful say before their shares are placed into securities lending channels.
网爆吃瓜 lending can serve legitimate market functions, but because it can facilitate short selling, the company believes investor consent should be explicit.
The request asks the SEC Staff to confirm it would not recommend enforcement action under Rule 17Ad-20 solely because CISO adopts and discloses the investor-consent framework described in the filing.
Commenting on the move, David Jemmett, CEO of CISO Global, says: 鈥淭his is about one simple principle: informed consent. If a shareholder's shares may be used in lending activity that can facilitate short selling, that shareholder should have the right to know, the right to decide, and the right to say no.
鈥淲e are asking the SEC Staff for clarity on a straightforward question: whether we can give our shareholders a meaningful, affirmative voice before their shares are made available for lending.鈥�
The proposed framework would mean shareholders would affirmatively opt in before their shares are treated as available for lending through the programme. Consent could be withdrawn at any time, subject to applicable settlement and recall mechanics.
Further, the programme would operate through existing shareholder-intermediary relationships and would not alter Depository Trust Company (DTC), National 网爆吃瓜 Clearing Corporation (NSCC), or other clearance and settlement infrastructure.
Nick Morgan, president of Investor Choice Advocates Network (ICAN), adds: 鈥淐ISO is using an established SEC process to seek clarity on a narrow but important question: whether investors can be given a meaningful, affirmative voice before their shares are made available for lending through existing intermediaries.
鈥淲e believe this consent-first framework is consistent with existing regulatory principles and serves the interests of beneficial owners and market transparency.鈥�
The programme is designed to give shareholders a direct voice in whether their shares may be made available for securities lending.
The filing follows the firm鈥檚 review of short-volume data, publicly reported fails-to-deliver during late 2025, and shareholder-record discrepancies that the company believes warrant greater transparency and investor choice.
CISO notes that short sale volume data and fails-to-deliver data have important interpretive limitations as described by the Financial Industry Regulatory Authority (FINRA) and the SEC, and their presence does not by itself establish abusive or unlawful activity.
The firm is not alleging in its no-action request that any specific intermediary or market participant engaged in unlawful conduct.
According to CISO, beneficial owners should have a meaningful say before their shares are placed into securities lending channels.
网爆吃瓜 lending can serve legitimate market functions, but because it can facilitate short selling, the company believes investor consent should be explicit.
The request asks the SEC Staff to confirm it would not recommend enforcement action under Rule 17Ad-20 solely because CISO adopts and discloses the investor-consent framework described in the filing.
Commenting on the move, David Jemmett, CEO of CISO Global, says: 鈥淭his is about one simple principle: informed consent. If a shareholder's shares may be used in lending activity that can facilitate short selling, that shareholder should have the right to know, the right to decide, and the right to say no.
鈥淲e are asking the SEC Staff for clarity on a straightforward question: whether we can give our shareholders a meaningful, affirmative voice before their shares are made available for lending.鈥�
The proposed framework would mean shareholders would affirmatively opt in before their shares are treated as available for lending through the programme. Consent could be withdrawn at any time, subject to applicable settlement and recall mechanics.
Further, the programme would operate through existing shareholder-intermediary relationships and would not alter Depository Trust Company (DTC), National 网爆吃瓜 Clearing Corporation (NSCC), or other clearance and settlement infrastructure.
Nick Morgan, president of Investor Choice Advocates Network (ICAN), adds: 鈥淐ISO is using an established SEC process to seek clarity on a narrow but important question: whether investors can be given a meaningful, affirmative voice before their shares are made available for lending through existing intermediaries.
鈥淲e believe this consent-first framework is consistent with existing regulatory principles and serves the interests of beneficial owners and market transparency.鈥�
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