The SEC denied a company’s request to undo a six-year-old trading suspension. That’s not the interesting part. The interesting part is what Commissioner Hester Peirce had to say about why the agency should bother reviewing these cases at all.

In a concurrence issued alongside the SEC’s opinion on June 25, 2026, Peirce argued that the review process for trading suspensions serves a purpose that extends well beyond any single case. Even when a suspension has already expired, the fallout for the targeted company can linger for years, making procedural review not just a formality but a genuine safeguard.

The No Borders case

The company at the center of this is No Borders, Inc., a non-reporting company that traded under the ticker NBDR. Back in April 2020, during the early chaos of the COVID-19 pandemic, the SEC ordered a trading suspension from April 6 to April 20.

The reason: No Borders had been making public statements about rapid COVID-19 test kits and medical supplies that were inconsistent with what the company had disclosed to the SEC.

The suspension came amid what the SEC described as drastic fluctuations in both trading volume and share prices for NBDR.

No Borders eventually petitioned to have the suspension terminated. The SEC’s response, captured in Release No. 34-105777, was a firm no. The Commission found that the original suspension was justified under Section 12(k) of the Securities Exchange Act, which requires only that the SEC determine the action is necessary in the public interest.

Peirce’s concurrence and why it matters

Peirce agreed with the outcome. But she used her concurrence to make a broader point about institutional process. Her argument centered on Rule of Practice 550, which governs how companies can petition for review of trading suspensions. Peirce stressed that the SEC should take these petitions seriously and review them in a timely manner.

When the SEC suspends trading in a stock, the downstream effects can be severe. In No Borders’ case, the company lost its eligibility for “piggyback” quoting under Rule 15c2-11. That rule allows broker-dealers to publish quotes for securities based on previously published quotes, without needing to independently verify the company’s information.

Losing piggyback eligibility happens when there’s a gap in quotations exceeding four business days. For a small, non-reporting company like No Borders, it essentially means the stock becomes much harder to trade.

Peirce’s point was that because these collateral consequences are so significant, the SEC has an obligation to ensure its review processes function properly. If a trading suspension turns out to have been unwarranted, the company needs a meaningful path to challenge it.

What this means for investors

Non-reporting companies operate without filing regular reports with the SEC, which means less public information is available. When one of these companies makes dramatic claims about pandemic health products, the information asymmetry between company insiders and retail investors can be enormous.

The loss of piggyback quotation eligibility is a practical consequence that investors in similar stocks should understand. Once a company loses that status, liquidity can evaporate, and fewer broker-dealers are willing to quote the stock.

Peirce’s concurrence adds a wrinkle worth watching. If the SEC’s internal review processes for trading suspensions become more robust, as she’s advocating, companies that are genuinely compliant get a fairer challenge process, while those making misleading claims face consequences that are harder to contest on procedural grounds.