Jan. 15, 2024
To whom it may concern, I am asking you not to allow the NYSE to list “Natural Asset Companies”. The free market must not be allowed to be manipulated. The efforts to financialize productive natural resources to subvert the legal system, pervert the capital markets, and to cause harmful outcomes for both investors and the US alike cannot be enabled. NACs bastardize the capital markets for a political objective, driven by a climate activist narrative. They are not only a new type of company but have also employed their own type of accounting system, the principles of which are not even narrowly accepted by the accounting profession. The use of their “made up” version of financial reporting raises innumerable red flags. NACs seek to control productive public and private land and other natural resources. Their stated purpose is not to make a profit or be productive, but to protect, conserve, and restore these “natural assets”, based on whatever their own definitions of those activities are. As you know, there are clear reasons that a company goes public. It is to access capital to provide both funding for growth and liquidity for existing investors. The path to achieve permission to be publicly traded is a rigorous and costly process. The NACs are a bastardization of that process. They aren’t seeking to manage resources to improve their earnings potential, but would often be seeking to remove the productivity of assets in the name of climate justice. Not only could this impact our ability to generate and access energy, minerals, water and food, but it could also put those decisions in the hands of foreign governments, giving them defacto control over America’s resources. The focus of the SEC is to protect investors. NACs allow investor money (they may not control i.e; pension funds) to be used to decommission resources and make them non-productive for political means. Americans and the SEC cannot allow that to happen. The bad outcomes 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. What is more frightening is that the United States could lose control of our food, water and energy supply at the hands of bad actors. Please consider the long term impact of this decision and do not allow NACs to access our capital markets via the NYSE listings or otherwise. The future of capitalism and the United States’ freedom may very well be at stake. Thank you for your consideration. Beth Odom