Jan. 12, 2024
To all involved at the SEC: I urge the SEC to reject the NYSE's proposal to list Natural Asset Companies (NACs), as per File No. SR-NYSE-2023-09. As a lifelong capitalist and seasoned professional in capital markets, I firmly believe in the necessity of fair and transparent market rules. Financializing natural resources through NACs, as proposed, risks undermining legal and financial systems, potentially leading to detrimental outcomes for investors and the U.S. economy. My extensive background, including being a broker-dealer and advising many consumers on financial offerings, informs my stance on investor protection. In my view, NACs distort capital markets for political aims. Their approach to creating a new accounting system - Statements of Ecological Performance - deviates alarmingly from standard financial reporting practices and raises serious concerns. NACs aim to control and manage natural resources not for profit or productivity but for conservation and preservation based on subjective definitions. This diverges from the fundamental purpose of public companies, which is to access capital for growth and provide returns to investors. The SEC's primary focus is investor protection. NACs could potentially misuse investor funds, including those from entities like pension funds, to decommission resources for political objectives. This threatens access to vital resources like energy and food and risks placing control over these assets in the hands of foreign entities or governments. In conclusion, NACs represent a departure from the fiduciary duty to prioritize investor interests. They risk consolidating critical resources under the control of a few, potentially even foreign actors. The SEC, as a guardian of fair and equitable markets, should not allow NACs to enter our capital markets through NYSE listings or any other means. I appreciate your attention to this matter and hope for a decision that prioritizes the integrity of our financial markets and the interests of all investors. Derek Seal