Subject: Regarding Rule File Number 10-244
From: Mike Cormack
Affiliation:

Sep. 6, 2024

September 6, 2024


Mike Cormack
3609 Mathers Ave
West Vancouver, BC V7V2K8
CANADA


Vanessa Countryman
Secretary, Securities and Exchange Commission


RE: The Green Impact Exchange Filing, Number 10-244

Dear Ms. Countryman,

Thank you for the opportunity to comment on the Green Impact Exchange (GIX) Filing. I am excited to see the next steps taken in furthering transparency around environmental impact compliance in the public securities markets.

As background, I started my career at American Century Mutual Funds in 1991, eventually managing the US Equity trade desk. After nine years at American Century, I moved to Chicago and joined Archipelago (then not yet an exchange) as President. I spent seven years there as we became a registered US Exchange, took ARCA public on our own exchange (a first at the time), became a dominant platform for ETF trading and listings, merged with the NYSE and acquired Euronext. After departing the NYSE as EVP, I moved to Vancouver, British Columbia and have been working at a venture capital fund, Renewal Funds, for the past 15 years. Renewal Funds has been a pioneer in ESG venture funding for early stage companies in North America. 

After spending so much time working with entrepreneurs striving for a greater good in the for profit sector, it is exciting to see the GIX breaking new ground in transparency and accountability. I have long wished for an ESG “seal of approval” for companies that I invest in and do business with. In our own experience at Renewal Funds impact reporting has been challenging over time with different standards being developed by different groups. 

In the public sphere I have watched with apprehension as various companies attempt to build green “brands”, particularly in areas where they might have historically been green offenders. At its best, we have solid organizations like B Corp; at its worst, we get greenwashing. None of these voluntary platforms have the regulatory teeth that an exchange does, and GIX addresses this. 

Finally, I will highlight the extensive experience of the team at GIX. There are tremendous advantages that come with living in the heavily regulated exchange world in terms of design, strategy and enforcement. These folks have the requisite backgrounds for success in a unique environment that not many people have experience operating in.

Thank you for your consideration.


Sincerely,



Mike Cormack





Regards, 
Mike Cormack 
mike.cormack@gmail.com 
mike@renewalfunds.com 
778-840-8997 - cell