Jan. 13, 2024
To all involved at the SEC: I urge the SEC to not allow the NYSE to list “Natural Asset Companies” or NACs, pursuant to File No. SR-NYSE-2023-09. I believe in free markets, doing so requires some ground rules, which cannot and must not be manipulated in order to keep the playing feel level and fair and to engender positive outcomes. The attempts to market and sell so-called “productive natural resources” subverts the economy, growth, and threatens the pursuit of happiness. Selling shares in purposefully unused natural resources is arrogant and counter productive. Enabling NACs allows the privileged rich to lock up resources that could be used to produce for individuals and the economy. Similarly NFT assets have come and gone in the passing fad of owning something fake with no real value. NACs are akin to a pyramid scheme and are anti human by keeping resources from being used by the human race out of arrogance and greed. 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.” (Source: https://investinginregenerativeagriculture.com/2022/11/29/douglas-eger/ ). Even if they use GAAP accounting within NAC financial reporting, their deception that there is some separate accounting measures to be used within the financial markets raises 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, but rather to remove them from being profitable or productive. It is a negative sum game except if they are given false credibility as a place of investment thus duping investors into a bad investment. To allow NACs would be enabling the next great loss of investments and people’s retirements and life savings. As should be well known, there is a very clear reason why a company goes public. It 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 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. These NACs aren’t seeking to manage resources to improve their earnings potential, rather they would often be seeking to remove the productivity of assets in the name of some type of climate justice. Not only could this impact 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. The purpose of the SEC is to protect 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 means. 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 other bad actors. Wall Street often cultivates a bad reputation and the SEC is supposed to be a counterbalance to make sure the markets are free and fair for everyone and have the interests of all investors at heart. Do the right thing, and not that which is politically-pushed and elite power-driven; do not allow NACs to access our capital markets via NYSE listings or otherwise. Thank you for your consideration. Glen Turnbow