Jan. 12, 2024
To the Commissioners at the SEC and all other individuals involved with File No. SR-NYSE-2023-09: I am writing to voice my strongest possible objection to the proposed formation and permission to list on the New York Stock Exchange the so-called “Natural Asset Companies” (or NACs) as described in File No. SR-NYSE-2023-09. After reviewing the details, I am TOTALLY AGAINST the concept of “Natural Asset Companies.” These proposed companies do not follow the accepted practices of publicly traded companies to access capital for the purpose of providing both funding for growth and liquidity for existing investors. Additionally, publicly traded companies provide opportunities for investors to participate in future growth for the risk they take on; this does not exist with NACs. Public companies are supposed to have strong merits and provide a path to growth for public investors in exchange. It is a rigorous and costly process both to become public and to stay public, and it is not for every business. NACs offer ZERO opportunity to allow the investor to grow his investment AND they open the door to bad actors taking control of strategic natural resources essential to the National Security of the United States. The NACs are nothing more than attempts to circumvent the American legal system, sabotage capital markets, and threaten the very survival of American citizens and United States of America. Any NAC would effectively control the land use of whatever property the NAC pays in its acquisition fee. This control of land use threatens America’s food supply, water supply, fuel supply and other natural resources (minerals, metals, timber, etc.). In fact, the entire purpose of an NAC could (and probably would) be to stop the land under its control from being used to maximize it’s commercial value – and that intentional effort would result in severe damage to the American people in the form of higher prices for all of the items (food, water, fuel, minerals and everything that uses them) mentioned above. NACs are also positioned to artificially create scarcity of essential items and prevent any use whatsoever of specific lands to the point of making certain currently-populated areas uninhabitable. By allowing Natural Asset Companies to be recognized and traded on the New York Stock Exchange, the SEC would be intentionally allowing harm to come to America’s ordinary citizens – the smallest and weakest members of our society. Those who are proposing NACs clearly recognize that these companies would be weapons used to harm other individuals or companies because they do not serve the purpose of independently building wealth for investors; the only legitimate financial purpose of an NAC is to help large investors who are looking to reduce pollution and carbon emissions through “carbon offsets.” Rather than pay whatever carbon taxes they may be required to satisfy in the future, polluting companies could continue to heavily pollute and the theoretical shares of NACs could allow them to do so without penalty. The fact that an NAC would never be required to turn a profit shows that those who purchase shares in NACs look at it as a tool to make others – those who do not have shares in the NAC – pay for their choice to pollute by requiring everyone to spend more on necessities as well as luxuries (or do without them). Worse, if NACs were permitted to be listed on the NYSE, investors in NACs would be unrestricted, which would permit wealthy individuals, corporations or even foreign sovereign wealth funds could use NACs to artificially damage the pricing and stability of natural resources – effectively holding hostage or crippling or destroying the U.S economy. For instance, if an NAC acquired land-management rights to the richest oil and gas fields in the United States, the NAC management could effectively shut them down, causing the price of gasoline and heating oil to spike, or if the OPEC nations were particularly hostile, they could refuse to sell any oil to the U.S., which would collapse our economy and potentially destroy the nation. While the argument can be made that the potential to dominate and control markets by removing assets from use is a small possibility, the fact that it exists at all shows the severity of this threat – it should NOT be permitted to happen. As a “new type of company,” NACs are proposing a new type of accounting system – a highly irregular, unproven and anti-capitalist plan that should require significant and detailed scrutiny over a long term before being considered as acceptable for investment by the public. It seems that the NACs clearly recognize the nefarious and intentionally harmful nature of their proposed companies, so they are using intentionally nonsensical terminology to describe this accounting system. The creator of NACs – IEG’s Chairman & CEO – described the accounting system thusly: “We created a new accounting system, which we called Statements of Ecological Performance, which account for the flow of ecosystem services in financial terms.” (Source: https://investinginregenerativeagriculture.com/2022/11/29/douglas-eger/). The leaders of the NACs want an accounting system that makes no financial sense and is intentionally unclear because they do not want to be held to standards that all other public companies must meet. It is entirely plausible (perhaps even likely) to believe his new accounting system was proposed because NAC accountants knew that these companies would NEVER be able to be considered for public trading if they were required to use GAAP accounting in their financial reporting. Being unable to fulfill basic filing requirements is clear evidence of the intentionally destructive purpose of NACs and this alone should immediately disqualify their application for trading of securities under control of the SEC. 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. 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. In short, rather than maximizing the earnings potential of the lands they manage, NACs seek to eliminate the productivity of these lands – a policy that would have destructive effects on individuals and the economy. The focus of the SEC has traditionally been protecting investors after the notorious stock market crash of 1929. 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. Americans and the SEC cannot allow that to happen. I vehemently encourage the SEC to DENY the request to allow NACs to be traded in the NYSE (File No. SR-NYSE-2023-09). It is in the best interests of all Americans to make sure that the natural assets of the United States are not potentially placed under the control of a few wealthy individuals, third-party companies or foreign countries; please do NOT permit the NACs to have access to the capital markets of the United States. Sincerely, JOHN CHUHRAN jtchuhran@netscape.com