Subject: File No. SR-NYSE-2023-09
From: Rodrigo Cubero

My name is Rodrigo Cubero. I am an international consultant in economics and law and Senior Counsel to BLP, the largest law firm in Central America. Prior to that I was President (Governor) of the Costa Rican Central Bank (2018-2022), staff member of the International Monetary Fund, and University Lecturer at the University of Oxford. I also worked as a corporate lawyer at KPMG Costa Rica. While serving as Central Bank Governor, I came to know the Intrinsic Exchange Group (IEG) and their initiative to create Natural Asset Companies (NACs). NACs are an innovative mechanism that will help serve four fundamental objectives in green finance. First, in a market where thus far all financing vehicles rely on some form of debt, NACs will help mobilize private funding for conservation efforts through the public listing of a NAC’s equity. This will provide a new and attractive investment option to complement standard lending-based instruments, as well as a bridge to help meet supply and demand in a market where there is an enormous financing gap. Second, the proposed operating and reporting frameworks for NACs ensure that investor resources are channeled, with full transparency and accountability, to the protection, preservation, and growth of ecosystems managed by the NACs in a way that also protects investor rights. Third, the financing mechanism through equity offerings requires that the ecosystem services provided by the NAC be thoroughly and properly valued, a much-needed step in protecting nature. And finally, the proposed benefit-sharing mechanisms will help ensure that the financial gains from, as well as the ecosystem services produced by, the NACs are shared equitably with local communities. For all these reasons, I wholeheartedly support IEG’s filing and the proposed rule change by the NYSE to adopt a new listing standard for NACs.