Jan. 13, 2024
To whom it may concern: I urge the SEC not to allow the New York Stock Exchange (NYSE) to list Natural Asset Companies (NACs), pursuant to File No. SR-NYSE-2023-09. NACs are a new type of company requiring great scrutiny, but they also have developed their own accounting system. The creator of NACs, Intrinsic Exchange Group's Chairman & CEO Douglas Eger, said, "We created a new accounting system, which we called Statement of Ecological Performance, which account for the flow of ecosystem services in financial terms." (Source: https://investinginregenerativeagriculture.com/2022/11/29/). Even if they use GAAP accounting within NAC financial reporting, the hubris that there are some separate accounting measures to be used within the financial markets raises a huge red flag. The focus of the SEC is protecting investors. Given the unique accounting measures and structure of NACs, potentially destructive outcomes will likely include the loss of the fiduciary duty to do what is in the best interest of investors. Additionally, critical natural resources could be subject to the consolidation of a handful of wealthy individuals and institutions, potentially giving them control over productive resources, including lands vital to our food supply, water, energy, tourism, and more. These ecosystems, previously deemed part of "the commons," could also end up in the hands of foreign nations and their sovereign wealth funds. The efforts to financialize productive natural resources pervert the capital markets and will cause harmful outcomes for investors. It cannot be enabled. I appreciate your consideration, Peter Smelser