Jan. 15, 2024
Subject: File No. SR-NYSE-2023-09 Asking the SEC to NOT ALLOW NACs To members of the SEC: I am urging the SEC to NOT allow the NYSE to list “Natural Asset Companies” or NACs, pursuant to File No. SR-NYSE-2023-09. As a business owner, I believe the continued efforts to financialize productive natural resources to subvert the legal system, to pervert the capital markets, and to cause harmful outcomes for both investors and the US alike cannot be enabled. It is clear that from an investor protection perspective, NACs use the capital markets for a political objective. The creator of the “NACs”, IEG’s Chairman & CEO, 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: investinginregenerativeagriculture.com/2022/11/29/dou…). 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 seek to use others’ money 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 protect, conserve, restore and preserve these natural “assets”, based on whatever their own definitions of those activities are. This cannot be good for the free market in America! Debbie Jones Charleston, SC