I am urging the SEC to NOT allow the NYSE to list “Natural Asset Companies” or NACs, pursuant to File No. SR-NYSE-2023-09. I am a capitalist to my core, but believing in free markets requires some ground rules, which cannot and must not be manipulated to keep the playing feel level and fair and to engender positive outcomes. The continued efforts to financialize productive natural resources to subvert the legal system, to pervert the capital markets, and to cause harmful outcomes for both investors and the US alike cannot be enabled. I have been in and around the capital markets my entire career. I owned my own broker-dealer at one point. I have advised on many IPOs and follow-on offerings in corporate finance. I have held various financial licenses. And, with such experience, it is clear that from an investor protection perspective, NACs bastardize the capital markets for a political objective. NACs are not only a “new type of company”, something that is highly irregular and should require much scrutiny, but also have employed their own type of accounting system. This comes directly from the creator of the “NACs”, IEG’s Chairman & CEO, who said has said, “We created a new accounting system, which we called Statements of Ecological Performance, which account for the flow of ecosystem services in financial terms.” (Source: