Jan. 12, 2024
Dear Members of the SEC, I am writing to strongly oppose the inclusion of "Natural Asset Companies" or NACs under File No. SR-NYSE-2023-09 and to urge the SEC to reject their listing on the NYSE. While I am a devoted supporter of capitalism and free markets, it is essential to establish and maintain rules that prevent manipulation and ensure fairness. The ongoing efforts to financialize natural resources for purposes beyond economic gains pose a threat to the legal system, distort capital markets, and have negative repercussions for both investors and the United States. NACs represent a departure from traditional company structures, requiring careful examination. Their implementation of a distinct accounting system, as acknowledged by IEG's Chairman & CEO, raises significant concerns, even if they claim adherence to GAAP accounting in their financial reports. The primary objective of NACs, utilizing external funds, including those raised in the capital markets, to control public and private land and natural resources, is troubling. Their goals, centered on protecting and conserving natural "assets" based on subjective definitions, deviate from the typical objectives of public companies seeking growth and profitability. The process of going public is designed for companies with strong merits and a path to growth for public investors. NACs, however, seem to prioritize environmental goals over financial gains, distorting the purpose of public companies. The potential impact on our access to critical resources such as energy, minerals, water, and food is alarming. Moreover, the decision-making power over these resources could fall into the hands of foreign governments and their sovereign wealth funds, compromising America's control over its resources. The SEC's primary focus is investor protection, and NACs pose a threat by enabling investor money, especially through entities they may not control, to be used for non-productive purposes driven by political motives. IEG's Chairman's acknowledgment that they sought a private-sector approach independent of policy, traditional taxes, regulation, or philanthropy emphasizes the political nature of NACs. This approach undermines fiduciary duty and risks consolidating control over critical resources in the hands of a few powerful individuals or foreign nations. While Wall Street may have a negative reputation, the SEC is tasked with ensuring fair and free markets for all investors. It is crucial to act in the best interests of investors and resist succumbing to politically-driven or elite power-driven agendas. I implore the SEC to uphold its principles and prevent NACs from accessing our capital markets through NYSE listings or any other means. Thank you for your consideration, Rodrigo Parra