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Keeping you in-the-know on environmental, social and governance developments

Interesting news yesterday – the New York Stock Exchange (NYSE) formally withdrew the proposal to create listing standards for Natural Asset Companies (NACs). The proposal defined a NAC as:

“… a corporation whose primary purpose is to actively manage, maintain, restore (as applicable), and grow the value of natural assets and their production of ecosystem services. In addition, where doing so is consistent with the company’s primary purpose, the company will seek to conduct sustainable revenue-generating operations. Sustainable operations are those activities that do not cause any material adverse impact on the condition of the natural assets under a NAC’s control and that seek to replenish the natural resources being used. The NAC may also engage in other activities that support community well-being, provided such activities are sustainable.”

The comment period was extended twice before this action. We originally covered the proposal here, saying:

“These [listing] requirements have to be approved by the SEC and would only apply to companies specifically seeking to qualify as a NAC. But for those that do, the compliance burden will be tough (to put it mildly).”

Yesterday’s letter notification of the decision did not include NYSE’s rationale, but they outlined concerns in their December notice that they were “instituting proceedings to allow for additional analysis of, and input from commenters.” Some in the sustainability/ESG world may lament NAC’s passing, but I don’t. The proposed listing requirements were highly burdensome and the purpose of NACs seemed rather contrived, confusing and potentially at odds with business fundamentals. Why do we need that?

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The Editor

Lawrence Heim has been practicing in the field of ESG management for almost 40 years. He began his career as a legal assistant in the Environmental Practice of Vinson & Elkins working for a partner who is nationally recognized and an adjunct professor of environmental law at the University of Texas Law School. He moved into technical environmental consulting with ENSR Consulting & Engineering at the height of environmental regulatory development, working across a range of disciplines. He was one… View Profile