May 20, 2024
Dear SEC Chair Gary Gensler, Please deny the proposal allowing for the creation and listing of Natural Asset Company (NAC) on the New York Stock Exchange (NYSE) and re-open the issue for public comment. If implemented, the proposal would have a catastrophic effect on rural economies by removing land from productive use. NACs would raise capital to purchase public and private land, such as forests, parks, and farms, and permanently lock it away from human impact. Unlike other company types, the goal of a NAC is not to make a profit, but rather to maximize the value of the land’s “ecological services.” Consequently, many essential economic activities would be permanently barred from occurring on the land. Under the proposal, private interests, including foreign-owned sovereign wealth funds, could purchase farmland and mineral-rich land and stop activities, such as grazing and energy extraction, in the name of solving climate change. This poses a significant risk of mis-allocating capital, locking up natural resources, and devastating rural economies by preventing productive utilization of the land. Thank you for your attention to this critical matter. I trust you will consider the best interests of our nation in evaluating and addressing this proposal. Regards,