Subject: File No.SR-NYSE-2023-09 Asking the SEC to NOT ALLOW NAC's
From: Rebecca
Affiliation:

Jan. 13, 2024

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 hubris 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 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 hubris 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 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 hubris 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 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 hubris 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. 
Thank you