Subject: File No. SR-NYSE-2023-09 Asking the SEC to NOT ALLOW NACs
From: Janet Pritchett
Affiliation:

Jan. 12, 2024

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 believe this scheme is an effort to financialize productive natural resources to subvert the legal system, to pervert the capital markets, and to cause harmful outcomes for both investors and the US alike. 

NACs are not only a “new type of company”, something that is highly irregular and should require much scrutiny, but also have employed their own type of accounting system. This comes directly from the creator of the “NACs”, IEG’s Chairman & CEO, who said has said, “We created a new accounting system, which we called Statements of Ecological Performance, which account for the flow of ecosystem services in financial terms.” 

Creating a new business type, new accounting systems and new investment vehicles are so radical they should not be implemented solely by an SEC approval. Congress, the IRS and the entire accounting industry should be involved in such a radical change.

Please 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.

Janet Pritchett, Retired CPA