Jan. 15, 2024
To SEC: I am urging the SEC to NOT allow the NYSE to list Natural Asset Companies or NACs in regard to File No. SR-NYSE-2023-09. NACs want to use other people's money to buy the ability to control or manage productive public and private land and other natural resources. Their stated purpose is not to make a profit, or be productive, but instead to protect, conserve, restore and preserve these natural "assets", based on whatever their own definitions of those activities are. As you know, there is a very clear reason that a company goes public. It is to broadly access capital to provide both funding for growth and liquidity for existing investors, providing opportunities for investors to participate in future growth for the risk they take on. Companies are supposed to have strong merits and provide a path to growth for public investors in exchange. These NACs will destroy that purpose. They aren't seeking to manage resources to improve their earnings potential, rather they would often be seeking to remove the productivity of assets in the name of some type of climate justice. Not only could this impact our ability to generate and access energy, critical minerals, water and food, but it could also put those decisions in the hands of institutions, such as foreign governments and their sovereign wealth funds, who could invest in these NACs and have indisputable control over America's resources. The most important role of the SEC is to protect 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. If you have any questions on whether this is a political tool meant to subvert the legal process, read the words of the 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." The bad outcomes here will include the subjugation of the fiduciary duty to 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 buffer to make sure the markets are free and fair for everyone and have the interest of all investors at heart. Please do the right thing and not what is politically-pushed and elite power-driven. Do not allow NACs to access our capital markets via NYSE listings or otherwise. I implore you to take a 30,000 ft. view of what is in the best interest of your children, grandchildren, and the future of the United States of America. It is not more control of the citizenry by a tiny group of people, foreign or domestic! Thank you for your consideration. Jerry Weaver