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. The efforts to highjack the control of 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 cannot be enabled. It is clear that from an investor protection perspective, NACs bastardize the capital markets for a political objective. 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. They 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 some type of climate justice. This would, no doubt, also be used by corporations to hamstring competition in the market by monopolizing or restricting access to natural resources and land use. Not only could this impact our ability to generate and access energy, critical minerals, water and food, but it could also put those decisions in the hands of institutions, such as foreign governments and their sovereign wealth funds, who could invest in these NACs and have de facto control over America’s resources. 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 and competitive advantage. Americans and the SEC cannot allow that to happen. 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. 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. The SEC is supposed to be a counterbalance to make sure the markets are free and fair for everyone and have the interests of all investors at heart. 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. Best regards, KM Norton Sent from my iPad