CISO Global Inc. (NASDAQ: CISO) filed a no-action request with the Securities and Exchange Commission seeking regulatory clarity for a proposed investor-consent framework that would give shareholders direct control over whether their shares can be used for securities lending.

The cybersecurity software company submitted the request following its review of short-volume data, publicly reported fails-to-deliver during late 2025, and shareholder-record discrepancies. The company stated it is not alleging unlawful conduct by any specific intermediary or market participant.

The proposed Investor-Consent Share Loan Program would require shareholders to affirmatively opt in before their shares become available for lending. Shareholders could withdraw consent at any time, subject to settlement and recall procedures. The program would operate through existing shareholder-intermediary relationships without altering current clearance and settlement infrastructure.

Nick Morgan, President of the Investor Choice Advocates Network, and Mark Hiraide are representing CISO Global pro bono in the filing. The request asks SEC staff to confirm they would not recommend enforcement action under Rule 17Ad-20 if the company adopts and discloses the proposed framework.

"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," said David Jemmett, CISO Global's chief executive officer.

The SEC staff response, if any, would reflect staff views only and would not constitute a formal rule or Commission approval. CISO Global noted there is no assurance regarding whether or when the SEC staff will respond to the request.

CISO Global provides AI-powered cybersecurity software and managed security solutions from its Scottsdale, Arizona headquarters.