Jan. 15, 2024
I am writing to urge the SEC to NOT allow the NYSE to list “Natural Asset Companies” or NACs, pursuant to File No. SR-NYSE-2023-09. I am a capitalist but believe that free markets require some ground rules, which cannot and must not be manipulated to keep the playing field level and fair and to engender positive outcomes. 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. The focus on the SEC is protecting investors. NACs allow investor money, particularly those deployed through entities that they may not control, such as pension funds, for example, to be used to decommission resources and make them non-productive for political means. Americans and the SEC cannot allow that to happen. Read the words of IEG’s Chairman, who said, “We were looking for a private-sector approach that wasn’t dependent on policy, it wasn’t dependent on traditional taxes, regulation or philanthropy to price in these assets and give investors the opportunity to invest directly in nature, whether that’s for climate or biodiversity.” (Source: https://eenews.net/articles/invest-in-nature-might-be-possible-with-natural-asset-companies/…). The bad 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. 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. That is terrifying to contemplate! The SEC is supposed to be a counterbalance to Wall Street to make sure the markets are free and fair for everyone and have the interests of all investors at heart. Do the right thing and do not allow NACs to access our capital markets via NYSE listings or otherwise. Sincerely, Andrea Guerrette