[Form 4] Tenable Holdings, Inc. Insider Trading Activity

Rhea-AI Filing Summary

Reporting person Seawell A. Brooke, a director of Tenable Holdings, Inc. (TENB), reported transactions dated 09/04/2025. The filing shows a sale/disposition of 4,622 shares of common stock at $30.12 per share (transaction code S) and additional dispositions totaling 9,230 shares and 15,000 shares reported as indirectly owned in trusts. Following the reported transactions, the filing lists 15,000 shares beneficially owned by an indirect trust. The explanatory notes state 4,622 shares were transferred on July 17, 2025, without consideration to the Rosemary and A. Brooke Seawell Revocable Trust; the reporting person is trustee of that trust and of the Alexander Brooke Seawell Revocable Trust. The Form 4 was signed by an attorney-in-fact on 09/05/2025.

Insights

Securities Analyst

TL;DR: Routine insider transfers to family revocable trusts and a reported disposition of 4,622 shares at $30.12 — appears administrative, not an operational signal.

The filing documents a mix of reported dispositions and transfers into trusts for Seawell A. Brooke, who is identified as a director. The sale/disposition of 4,622 shares at $30.12 is explicit; explanatory notes clarify that those shares were transferred without consideration to a revocable trust on July 17, 2025. The reporting person is trustee of two named family trusts. Given the nature of transfers to affiliated trusts and the filing being signed by an attorney-in-fact, this record is consistent with estate-planning or administrative re-titling rather than a direct change in operational exposure. No derivative transactions or other compensation-related issuances are reported.

Corporate Governance Expert

TL;DR: Director re-titling and disposition to trusts documented; disclosure meets Section 16 reporting requirements with clear trustee relationships.

The Form 4 provides the necessary Section 16 disclosure: transaction codes, share amounts, and ownership form (direct versus indirect). It identifies the reporting person as a director and as trustee for two revocable trusts, with one transfer explicitly noted as occurring without consideration. The signature by an attorney-in-fact is included. From a governance perspective, the entry clarifies beneficial ownership structure but does not indicate a governance change, compensation event, or related-party transaction beyond trustee roles disclosed.

SEC Form 4

FORM 4

UNITED STATES SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549

STATEMENT OF CHANGES IN BENEFICIAL OWNERSHIP

Filed pursuant to Section 16(a) of the Securities Exchange Act of 1934
or Section 30(h) of the Investment Company Act of 1940

OMB APPROVAL

OMB Number:			3235-0287
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hours per response:			0.5

Check this box if no longer subject to Section 16. Form 4 or Form 5 obligations may continue. See Instruction 1(b).

Check this box to indicate that a transaction was made pursuant to a contract, instruction or written plan for the purchase or sale of equity securities of the issuer that is intended to satisfy the affirmative defense conditions of Rule 10b5-1(c). See Instruction 10.

1. Name and Address of Reporting Person^*

SEAWELL A BROOKE

(Last) (First) (Middle)

C/O TENABLE HOLDINGS, INC.

6100 MERRIWEATHER DRIVE

(Street)

COLUMBIA MD 21044

(City) (State) (Zip)

2. Issuer Name and Ticker or Trading Symbol
Tenable Holdings, Inc. [ TENB ]

5. Relationship of Reporting Person(s) to Issuer
(Check all applicable)

X	Director		10% Owner
	Officer (give title below)		Other (specify below)

3. Date of Earliest Transaction (Month/Day/Year)
09/04/2025

4. If Amendment, Date of Original Filed (Month/Day/Year)

6. Individual or Joint/Group Filing (Check Applicable Line)

X	Form filed by One Reporting Person
	Form filed by More than One Reporting Person

Table I - Non-Derivative Securities Acquired, Disposed of, or Beneficially Owned
1. Title of Security (Instr. 3)	2. Transaction Date (Month/Day/Year)	2A. Deemed Execution Date, if any (Month/Day/Year)	3. Transaction Code (Instr. 8)		4. Securities Acquired (A) or Disposed Of (D) (Instr. 3, 4 and 5)			5. Amount of Securities Beneficially Owned Following Reported Transaction(s) (Instr. 3 and 4)	6. Ownership Form: Direct (D) or Indirect (I) (Instr. 4)	7. Nature of Indirect Beneficial Ownership (Instr. 4)
			Code	V	Amount	(A) or (D)	Price
Common Stock	09/04/2025		S		4,622	D	$30.12	15,000(1)	I	Trust(2)
Common Stock								9,230(1)	D
Common Stock								15,000	I	Trust(3)

Table II - Derivative Securities Acquired, Disposed of, or Beneficially Owned (e.g., puts, calls, warrants, options, convertible securities)
1. Title of Derivative Security (Instr. 3)	2. Conversion or Exercise Price of Derivative Security	3. Transaction Date (Month/Day/Year)	3A. Deemed Execution Date, if any (Month/Day/Year)	4. Transaction Code (Instr. 8)		5. Number of Derivative Securities Acquired (A) or Disposed of (D) (Instr. 3, 4 and 5)		6. Date Exercisable and Expiration Date (Month/Day/Year)		7. Title and Amount of Securities Underlying Derivative Security (Instr. 3 and 4)		8. Price of Derivative Security (Instr. 5)	9. Number of derivative Securities Beneficially Owned Following Reported Transaction(s) (Instr. 4)	10. Ownership Form: Direct (D) or Indirect (I) (Instr. 4)	11. Nature of Indirect Beneficial Ownership (Instr. 4)
				Code	V	(A)	(D)	Date Exercisable	Expiration Date	Title	Amount or Number of Shares

Explanation of Responses:

1. Reflects 4,622 shares transferred on July 17, 2025, without consideration, from the Reporting Person to The Rosemary and A. Brooke Seawell Revocable Trust (Administrative Trust).

2. Reporting Person is the Trustee of the Rosemary and A. Brooke Seawell Revocable Trust (Administrative Trust).

3. Reporting Person is Trustee of the Alexander Brooke Seawell Revocable Trust.

Remarks:

	/s/ David Bartholomew, Attorney-in-Fact	09/05/2025
	** Signature of Reporting Person	Date
Reminder: Report on a separate line for each class of securities beneficially owned directly or indirectly.
* If the form is filed by more than one reporting person, see Instruction 4 (b)(v).
** Intentional misstatements or omissions of facts constitute Federal Criminal Violations See 18 U.S.C. 1001 and 15 U.S.C. 78ff(a).
Note: File three copies of this Form, one of which must be manually signed. If space is insufficient, see Instruction 6 for procedure.
Persons who respond to the collection of information contained in this form are not required to respond unless the form displays a currently valid OMB Number.

FAQ

What transactions did TENB director Seawell A. Brooke report on Form 4?

The filing reports a disposition of 4,622 shares at $30.12 and additional reported dispositions/indirect holdings of 9,230 and 15,000 shares tied to trusts.

Were any shares transferred to trusts by Seawell A. Brooke?

Yes. The explanatory notes state 4,622 shares were transferred on July 17, 2025, without consideration to the Rosemary and A. Brooke Seawell Revocable Trust; the filer is trustee of that trust and of the Alexander Brooke Seawell Revocable Trust.

What is the reporting person’s relationship to TENB?

The filing identifies Seawell A. Brooke as a Director of Tenable Holdings, Inc.

When were the transactions and when was the Form 4 signed?

The earliest transaction date listed is 09/04/2025, and the Form 4 bears a signature by an attorney-in-fact dated 09/05/2025.

Does the Form 4 show any derivative security transactions for TENB?

No. Table II for derivative securities contains no reported transactions in this filing.