Jan. 13, 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. I believe that free market capitalism is the best economic system to "raise all boats". It allows those entrepreneurs who are courageous but perhaps not business-savvy to participate, and even if they don't make the millions that others have, they have contributed to our society in ways that are uncountable. NACs bastardize the capital markets for a political objective. NACs are not only a “new type of company”, something that is highly irregular and should require much scrutiny, but also have employed their own type of accounting system. This comes directly from the creator of the “NACs”, IEG’s Chairman & CEO, who said has 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.” (Sounds like a lot of hogwash to me!) (Source: https://investinginregenerativeagriculture.com/2022/11/29/douglas-eger/). Even if they use GAAP accounting within NAC financial reporting, their hubris that there is some separate accounting measures to be used by their special company, and if it falls within the financial markets, it will raise too many red flags to count and should be immediately disqualifying. 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 [against what the SEC requires!], but rather to protect, conserve, restore and preserve these natural “assets”, based on their own definitions of what those activities are. A very clear reason that a company goes public is to broadly access capital to provide both funding for growth and liquidity for existing investors, providing opportunities for investors to participate in future growth for the risk they take on. Companies use a rigorous and costly process both to become public and to stay public, and it is not for every business. These NACs are a bastardization of that purpose. They aren’t seeking to manage resources to improve their earnings potential. Rather they often seek to remove the productivity of assets in the name of some type of theoretical science, made up from wishes and feelings, not using real world science. (i.e., carbon neutrality; methane overload; nitrogen toxicity (?????)) Because these NACs want to be publicly traded in our country's market, it opens the door to foreign governments and their sovereign wealth funds, which could invest in these NACs and have de facto control over America’s resources. It opens another source of national security risk to our already-at-risk country. The focus on the SEC is protecting investors. NACs allow investor money to be used to decommission resources and make them non-productive for political means. Americans and the SEC cannot allow that to happen. Bad outcomes here can include the lack 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 our country's political and military enemies. And the SEC should not aid this to happen by allowing the NYSE to list “Natural Asset Companies” or NACs. Please consider the county first when you discuss this action.