Jan. 12, 2024
To Whom It May Concern: 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. To allow this would compromise the absolute need to keep a level playing field and to promote positive outcomes in a free market system. This action, if enabled, would subvert the legal system, pervert the capital markets, and cause harmful outcomes for both investors and the U.S. These NACs, if enabled, would serve political objectives more than anything else. It is not surprising that this new kind of company has also developed their own type of accounting system. The creator of the NACs, IEG’s Chairman & CEO, 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.” Again, this action would serve political interests rather than providing a vehicle for sound fiduciary interests. To think these people could use separate accounting measures to be used within the financial markets raises many red flags. Bottom line, NACs are NOT seeking to manage resources to improve their earnings potential, but rather, could be seeking to remove the productivity of assets in the name of some type of climate justice. In addition to impacting 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. NAC’s create the opportunity for decommissioning resources and making them non-productive for political interests. That NACs would serve as a political tool used to subvert the legal process was reflected in the comments of IEG’s Chairman, who said, “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: renews,n et/articles/inves…). In conclusion, some of the reasons to NOT allow the NYSE to list NACs include the following planned or unplanned ramifications of implementation: 1) The subjugation of the fiduciary duty to do what is in the best interest of investors, 2) Critical natural resources will be subject to the consolidation of a handful of wealthy and powerful individuals. Even worse, 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. I urge you, in the interest of guaranteeing markets to be free and fair for everyone, having the interests of all investors at heart (rather than that which is politically--pushed and elite power-driven) to do what the SEC is supposed to do. The role of the SEC is to protect investors. Say NO to Natural Asset Companies being listed on the NYSE. Thank you for your consideration. Barbara Heath