Jan. 17, 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. I am a small business advocate and free-market capitalist. We all know that the continued efforts to CONTROL and financialize natural resources to subvert the legal system, manipulate the capital markets, and cause harmful outcomes for both investors and the America alike is WRONG, plain and simple. The free-market economy has created the most prosperous and productive and economy in the history of mankind. While the SEC proposal may seem beneficial and well-meaning, it is fraught with red flags, perils and pitfalls, especially for rural communities in the West. Consider the “significant risks” of this SEC proposal, cited by Utah’s state treasurer Mario Oaks, in this article in The Dallas Express (“SEC Masks the True Impact of Natural Asset Companies” 1/15/24): · First, the SEC proposal creates a mechanism for public and PRIVATE land to be “permanently removed from PRODUCTIVE use in the name of solving climate change.” (Because the SEC proposal is so obviously unconstitutional, the SEC would be tied up in legislation for YEARS – in the name of an ideology that has as many detractors as supporters. Seriously. has the SEC considered the EV debacle – electric cars losing 40% of their charge in the recent frigid weather, major automakers pausing EV and battery production, Hertz abandoning its push to foist EVs on customers, the geo-political realities of mining essential battery minerals in Africa, etc.???) · “The proposed creation of Natural Asset Companies is one of the greatest THREATS to rural communities in the history of our country. Under the proposal, private interests, including FOREIGN-controlled wealth funds, could use their capital to purchase or manage farmland, national and state parks, and other mineral-rich areas and stop essential economic activities like farming, grazing, and energy extraction.” (Is the SEC aware that the Chinese Communist Party has purchased more than 352,000 acres of American farmland as of 2020, according to the Heritage Foundation?) · Unlike other companies that generate a profit from traditional activities and are accountable to investors, “the purpose of an NAC is to maximize the value of the land’s ecological services.” In short, according to Mario Oaks, “If a a government-owned area gets designated NAC-managed land, all use of farm machinery and synthetic fertilizers would be prohibited, as well as extractive activities.” · Like Utah, Texas has abundant rural farmland and Oaks says, “In western states, where the federal government owns more than half of the land and is pushing for more conservation easements, the effect could be devastating. Natural Asset Companies could acquire the easements without the landowners’ consent.” And if Utah treasurer Mario Oaks’ comments above aren’t enough to make the SEC think twice about this risky, unconstitutional proposal, consider the conclusion of The Dallas Express staff writer Andrew Terrell who wrote the above article: “It’s clear that from an investor protection perspective, NACs bastardize the capital markets for a political objective.” Lastly, seriously consider the comments by IEG’s own Chairman & CEO who created the NACs and pointed out that NACs are not only a “new type of company” requiring much scrutiny, but ALSO one employing their own type of accounting system. The creator of the NACs 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/…). I agree with writer Andrew Terrell’s assessment about this SEC proposal: “Even if they (IEG) 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. 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.” Given today’s geo-political reality, this is Terrell’s most relevant point about the dangers of NACs: “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.” Are these the risks the Security Exchange Commission is willing to bear? Thank you for considering my comments and voting a resounding NO on adding NACs to the New York Stock Exchange. Sincerely, Virginia David [REDACTED]