The Securities and Exchange Commission's (SEC) Division of Corporation Finance has issued a no-action letter to DoubleZero, dated September 29, 2025. This letter states that the Division will not recommend enforcement action if Programmatic Transfers, as described in DoubleZero's incoming letter, are conducted without registration under Section 5 of the Securities Act and without 2Z being registered as a class of equity securities under Section 12(g) of the Exchange Act. This position is contingent on the specific facts and circumstances presented and does not constitute a legal conclusion.

This guidance provides clarity for entities considering similar programmatic transfer structures. While non-binding, it indicates the SEC staff's current enforcement stance. Companies contemplating such transfers should carefully review the conditions outlined in the no-action letter and ensure their operations strictly adhere to the described facts and circumstances to rely on this position. No specific compliance deadline is mentioned, as this is an interpretive letter based on a specific request.