Subject: File No. SR-NYSE-2023-09
From: eric rogge

Potential Pitfalls: Financialization of Nature: Speculation and Commodification: There's a risk that the creation of financial instruments tied to natural assets may lead to speculation and commodification, potentially prioritizing short-term financial gains over long-term environmental sustainability. Social Equity Concerns: Displacement and Access: Projects associated with NACs could impact local communities, leading to concerns about land rights, displacement, and access to natural resources. Market Volatility and Externalities: Market Risks: Dependence on financial markets introduces the risk of market volatility, potentially affecting the economic viability of NACs. Unintended Consequences: Financialization of natural assets may lead to unintended consequences, such as the neglect of non-monetized ecological values. Regulatory Challenges: Regulatory Oversight: Effective regulation is crucial to prevent abuse and ensure that NACs operate in line with environmental and social goals. Insufficient regulatory oversight could lead to negative outcomes. Complexity and Transparency: Complex Financial Instruments: The creation of complex financial instruments may pose challenges in terms of transparency, understanding, and oversight, potentially leaving room for financial engineering that doesn't align with environmental objectives. Long-Term Viability: Sustainability of NAC Models: The long-term success of NACs depends on their ability to balance financial returns with ecological sustainability. Ensuring that the financial incentives align with genuine environmental benefits is crucial.