Subject: File No. SR-NYSE-2023-09
From: Matthew Schnurr

Natural Asset Companies must not be approved by the SEC. Commoditizing something as nebulous as “ecological performance” is ripe for abuse by unscrupulous actors and, in any other case, would be considered a smokescreen for blatant fraud. This will make detecting, investigating, and stopping abusive & fraudulent behavior on the part of bad actors nearly impossible if they hide it behind a NAC. Furthermore, there is no mechanism to ensure that the ecological goals set forth by any NAC will actually have a positive impact on the environment under their charge. The removal of an invasive species may violate the biodiversity goal of a NAC despite the obvious ecological benefits of removing it.