Jan. 12, 2024
?To whom it may concern 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. This new rule will change the playing field and manipulate the rules for citizens and investors participating in a free market, resulting in harmful outcomes for them. I worked in financial services as an institutional trader for the majority of my career. Based on this experience, it is clear to me that NACs corrupt the capital markets for political purpose and are a danger to maintaining a free republic. NACs and the new accounting systems they utilize based on ecological performance are highly concerning. They raise too many red flags which should make them null and void and ineligible for consideration. NACs seek to use capital from others 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. Companies go public to broadly access capital to provide both funding for growth and liquidity for existing investors, thereby creating opportunities for investors to participate in future growth for the risk they take on. Companies are supposed to have strong fundamentals and provide a path to growth for public investors in exchange. It is a rigorous and expensive process both to become public and to stay public, and it is not for every business. NACs aren’t seeking to manage resources to improve their earnings potential, but rather they would see to eliminate the productivity of assets in the name of climate justice limiting our ability to generate/access energy, essential minerals, and food/water. It effectively puts those decisions in the hands of large institutions, such as foreign governments, who could invest in NACs and control America’s resources. The SEC’s main priority should be 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 purposes. Americans and the SEC cannot allow that to happen. The IEG’s Chairman exposed their true intent saying, “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/). The fiduciary duty to do what is in the best interest of investors will be abandoned and critical natural resources will be subject to the consolidation of a handful of wealthy and powerful individuals. Control of productive resources- as well as our food supply, water, and energy could end up in the hands of foreign nations and their sovereign wealth funds or other bad actors. Wall Street has a corrupt reputation and the SEC is supposed to ensure the markets are free and fair for everyone. I am writing to request that the SEC not allow NACs to access our capital markets and further empower the elite to have control over our nation’s resources to achieve a political means. Do not allow NACs to access our capital markets via NYSE listings or otherwise. Thank you for your consideration. Angela Fox Sent from my iPhone