Subject: File No. SR-NYSE-2023-09
From: Drew Izatt

After considering points made by others, I strongly oppose the efforts that are being made to allow Natural Asset Companies to be listed on any stock exchange and urge the SEC to NOT allow the NYSE to list “Natural Asset Companies” or NACs, pursuant to File No. SR-NYSE-2023-09. I agree with others who have made the following comments: NACs seek to use others’ money, including that obtained via the capital markets, to buy the ability to control or “manage” productive public and private land and other natural resources. Their stated purpose in doing so is not to make a profit or to be productive, but rather to protect, conserve, restore and preserve these natural “assets”, based on whatever their own definitions of those activities are. It is clear that from an investor perspective, NACs are using the capital markets for a political objective. There is a very clear reason that a company goes public. It is to broadly access capital to provide both funding for growth and liquidity for existing investors, providing opportunities for investors to participate in future growth for the risk they take on. Companies are supposed to have strong merits and provide a path to growth for public investors in exchange. It is a rigorous and costly process both to become public and to stay public, and it is not for every business. They aren’t seeking to manage resources to improve their earnings potential, rather they would often be seeking to remove the productivity of assets in the name of some type of climate justice. Not only could this impact our ability to generate and access energy, critical minerals, water and food, but it could also put those decisions in the hands of institutions, such as foreign governments and their sovereign wealth funds, who could invest in these NACs and have de facto control over America’s resources. The focus on the SEC is protecting investors. NACs allow investor money, particularly those deployed through entities that they may not control, such as pension funds, for example, to be used to decommission resources and make them non-productive for political means. Americans and the SEC cannot allow that to happen. The SEC is supposed to be a counterbalance to make sure the markets are free and fair for everyone and have the interests of all investors at heart. Do the right thing, and not that which is politically-pushed and elite power-driven; do not allow NACs to access our capital markets via NYSE listings or otherwise. Thank you for your consideration in this matter.