Call me crazy but I think it is unlikley that in March 2020 someone from the FDA said "Yes we understand that 50 HIV patients have been dosed weekly with 700 mg for the last five years with zero safety signals, but we still think its a good idea to limit to two doses."
I think more likely the two CD12 doses resulted from the chaos of March 2020 combined with Cytodyn's less than stellar communications skills.