Jan. 5, 2024
??Subject: File No. SR-NYSE-2023-09 Asking the SEC to NOT ALLOW NACs To all involved at the SEC: 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 have been in and around the capital markets my entire professional life, and I have worked directly and indirectly with the resources sector. NACs seek to exert control over the resources sector for the promotion and extension of a political objective. In the words of the “NACs”, IEG’s Chairman & CEO: “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: https://investinginregenerativeagriculture.com/2022/11/29/douglas-eger/). Even if they use GAAP accounting within NAC financial reporting, their hubris that there is some separate accounting measures to be used within the financial markets raises too many red flags to count and should be immediately disqualifying. 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. This wording opens a door to massive and potentially irreparable malfeasance. Companies go public to broadly access capital to provide both funding for growth and liquidity for existing investors while providing opportunities for investors to participate in future growth for the risk they take KNOWINGLY accept. NACs 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 their “self-defined climate justice”. 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. If you have any questions on whether this is a political tool meant to subvert the legal process, read the words of IEG’s Chairman, who said, “We were looking for a private-sector approach that wasn’t dependent on policy, it wasn’t dependent on traditional taxes, regulation or philanthropy to price in these assets and give investors the opportunity to invest directly in nature, whether that’s for climate or biodiversity.” (Source: https://eenews.net/articles/invest-in-nature-might-be-possible-with-natural-asset-companies/). This statement alone is damning in that it clearly states that the objective of NACs is to subvert / circumvent policy of duly ELECTED officials. The bad outcomes here will include the subjugation of the fiduciary duty to do what is in the best interest of investors. Critical natural resources will be subject to the consolidation of a handful of wealthy and powerful individuals (funds). And, even more frightening, control of productive resources- as well as our food supply, water, energy, tourism and more- could end up in the hands of foreign nations and their sovereign wealth funds or other bad actors. Thank you for your urgent consideration of this matter. The SEC is being called on to protect the integrity of a democratic society of elected representatives to insure that the political ideologies of certain non-elected, powerful voices do not create a method to gain control of the resources of this nation. Sent from my iPad