Subject: File No. SR-NYSE-2023-09 Asking the SEC to NOT ALLOW NACs
From: Jean Young
Affiliation:

Jan. 16, 2024

To All Involved at the SEC: 

Please do NOT allow the NYSE to list “Natural Asset Companies” or NACs, pursuant to File 
No. SR-NYSE-2023-09. I believe in free markets that are not manipulated. Financializing 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 must not happen. 

Changing capital markets for a political objective.and creating a unique accounting method for NACs is inappropriate. 

When a company goes public, it is to 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. It is a rigorous and costly process both to become public and to stay public, and it is not for every business. 


These NACs are a bastardization of 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 de facto control over America’s resources. 

Do the right thing,-- do not allow NACs to access our capital markets via NYSE listings or otherwise. 

Thank you for your consideration. 


Jean Young 
Ardmore Communications 
562.857.2427 cell 
ardmore.communications@gmail.com 
jean@ardmorecommunications.com