Jan. 14, 2024
I ask you to not allow the NYSE to list NACs. Operating in free markets requires ground rules that must not be manipulated, to keep the playing field level and fair and to engender positive outcomes. Continued efforts to financialize productive natural resources to subvert the legal system and capital markets, and to cause harmful outcomes for investors and the US, should not be enabled. It is clear that from an investor perspective, that 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, the Independent Evaluation Group (IEG)’s Chairman & CEO, who said, “We created a new accounting system, which we called Statements of Ecological Performance, which accounts for the flow of ecosystem services in financial terms.” (Source: https://investinginregenerativeagriculture.com/2022/11/29/douglas-eger/). The negative outcomes here will include the subjugation 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 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 not allow NACs to access our capital markets via NYSE listings or otherwise. Thank you. David M Humphrey [REDACTED]