Jan. 16, 2024
To all involved at 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. It is clear that from an investor protection perspective, NACs bastardize the capital markets for a political objective. NACs are not only a “new type of company”, something that is highly irregular and should require much scrutiny, but also have employed their own type of accounting system. This comes directly from the creator of the “NACs”, IEG’s Chairman & CEO, who said has 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: https://investinginregenerativeagriculture.com/2022/11/29/douglas-eger/…). 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. Not only could this action impact our ability to generate and access energy, critical minerals, water and food, but it could also put those decisions in the control of foreign owners who may be hostile to this country. It is a question of national security that this approval be denied. The SEC is supposed to be a counterbalance 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 not that which is politically-pushed and elite power-driven; do not allow NACs to access our capital markets via NYSE listings or otherwise. Thank you for your consideration.