Subject: File No. SR-NYSE-2023-09
From: Lucinda Houtchens

On September 14, 2021, the NYSE (New York Stock Exchange) and IEG (Intrinsic Exchange Group) announced that they were jointly developing a new class of publicly traded assets called Natural Asset Companies (NACs) to be sustainable enterprises that hold the rights to ecosystem services produced by natural, working, or hybrid lands. WAIT! Shouldn’t the landowner hold these rights? Isn’t it telling that the NYSE is an investor in IEG. This is an egregious conflict of interest! We all agree that nature is priceless. But just because nature’s value has not been counted or monetized as the NACs propose to do now, it does not mean that it should be monetized! Land grabs, fraud, and the dissolution of personal property rights are the unwritten focus of these NACs. Fast forward to October 2023 when the SEC proposed a rule to approve the creation of the NACs. Proposing (issuing) a rule does not in any way make it LEGAL! Why does the SEC believe it has the power to approve the NACs simply by creating a new rule? And why did the SEC initially allow a very short period for comments concerning this rule? Perhaps they knew it could be illegal. The SEC should not be permitted to give IEG and the NYSE the right to appropriate and put price tags on natural assets of property belonging to private citizens, on property that belongs to all U.S. citizens (our National Parks, for instance), and on other publicly held lands or conservation easements. The SEC should not be permitted to allow IEG and the NYSE to sell and trade these NACs to investors, including foreign actors who could be enemies or adversaries of our country, because they would gain management control over these lands. Shouldn’t landowners manage and control their lands? Shouldn’t U.S. citizens through their representatives manage our public lands? Clearly, the intent of NACs is to steal landowner’s property rights! BOTTOM LINE: These NACs are ILLEGAL and SHOULD BE STOPPED before this LAND GRAB SCHEME ends in wasted years of LAWFARE!!