Subject: RE: SR-NYSE-2023-09 Release No. 34-98879
From: Mary M. Britt
Affiliation:

Jan. 12, 2024

RE: File No. SR-NYSE-2023-09 Release No. 34-98879 

Dear Commissioners,
I write to express my concerns relating to Natural Asset Companies (or “NACs”). 
The creation of an entirely new corporate taxonomy based on protecting public natural resources by placing them under the direction of NACs raises significant questions about asset valuation, investment risk, and corporate accountability. I believe that a comprehensive evaluation of the unique listing requirements relating to NACs is critical to safeguard the interests of potential investors. The proposed rule would allow for federal lands, including national parks and other publicly owned lands, to be included in private investment portfolios. The proposed rule also allows for NACs to have management authority over assets held in the portfolio, including our public lands.
In the proposed rule, the SEC is creating a new incentive for non-government corporate control over our publicly shared lands. I am concerned that corporate involvement in the stewardship and control of our federal lands would create unintended consequences. The proposed rule could lead to a preservationist-only approach to federal land management instead of an “all-of-the-above” working lands approach as intended by the creation of our federal land programs. 
I am also alarmed by the SEC’s allowance under the proposed rule of foreign investment in these uniquely U.S. assets. At a time in which we are actively working to deter our adversaries, we should not open our federal lands up to investment from the same adversaries. 
In Summary, the proposed rule is fraught with concerns and very real negative and unintended consequences to the interests of the United States. Please do not approve it. 
Sincerely,
Mary M. Britt
[REDACTED]