Jan. 15, 2024
To all involved at the SEC: I am requesting the SEC to NOT allow the NYSE to list “Natural Asset Companies” ( NACs), pursuant to File NO. SR-NYSE-2023-09. This is an effort to “financialize" productive natural resources to subvert the legal system, to pervert capital markets, and to cause harmful outcomes for investors and the United States alike. NACs are a new type of entity, employing a new accounting system called Statements of Ecological Performance, which purports to account for the flow of ecosystem services in financial terms. Even if they use GAAP accounting, the notion that there is some separate accounting measures to be used within the financial markets raises red flags and poses a threat to standard accounting principles. NACs purport to use others’ money, including money obtained via capital markets, to purchase the ability to control or manage productive public or private land and other natural resources. The stated purpose is to protect, conserve, restore and preserve these natural “assets," based on their OWN definitions of what those activities are. On the contrary, a company goes public to access capital to provide funding for growth and liquidity for existing investors, providing opportunity for investors to participate in growth for the risk they take on. NACs, on the other hand, do not seek to manage resources to improve their earning potential; rather, they could remove the productivity of assets in the name of some sort of ill-defined climate justice. The danger for the United States is that NACs could impact our ability generate and access energy, critical minerals, water, and food. Decisions as to the assets could be made by institutions such as foreign governments and their sovereign wealth funds allowing these institutions to have de facto control over American resources. The purpose of the SEC is to protect investors. The bad outcomes include subjugating the fiduciary standard regarding investors, to the purposes of a handful of wealthy and powerful individuals who control institutions which will exercise undue control of American resources. Credits: Paraphrase of Carol Roth comments submitted to the SEC re File No. SR-NYSE-2023-09. In sum, by this timely comment, I am requesting that the SEC NOT allow NACs to access our capital markets via NYSE listings or otherwise. Thank you for your consideration. Maureen D. Carman, 701 Mount Vernon Drive, Lexington, KY