The following Letter Type A, or variations thereof, was submitted by individuals or entities.

Letter Type A:

This comment is relating to File No. 10-244. Add this comment to the record.
I am writing to strongly oppose the application by Green Impact Exchange LLC (GIX) to register as a National Securities Exchange. The proposal by GIX, if approved, would not only introduce a new financial market driven by environmental, social, and governance (ESG) metrics but would also pave the way for an alarming corporate takeover of natural resources that belong to the American people.
At its core, the Green Impact Exchange's model seeks to monetize natural assets and ecosystem services-converting essential functions of nature, like pollination and water purification, into tradeable assets. This fundamentally transforms our natural resources into commodities under the control of powerful institutional investors. The result would be a concentrated, unchecked influence over public and private lands by a handful of corporate giants and billionaires. These entities would stand to profit immensely from assets that were previously protected and preserved for public benefit, not private gain.
The ESG framework, championed by major institutional investors such as BlackRock, is used as a vehicle to enforce sustainable development goals through mechanisms like the Paris Climate Agreement. Corporations wishing to list on GIX will be bound by ESG compliance mandates, effectively pressuring them to align with policies that may lack transparency, accountability, and true environmental or social value. This system imposes “Green Governance Standards” that further cements the role of corporations as custodians of environmental and social assets, bypassing public oversight and democratic decision-making.
Furthermore, GIX's structure would allow for the future listing of Natural Asset Corporations (NACs), entities created to monetize ecosystem services and natural resources through financialization. In practice, NACs would manage vast tracts of land and critical ecosystem functions, with ownership rights derived through agreements with federal agencies like the Bureau of Land Management and the National Park Service. This means that, under GIX, private entities would gain unprecedented influence over public lands and resources, effectively sidelining the voices of everyday Americans. It raises grave concerns about accountability and the public's ability to challenge decisions that directly impact access to and stewardship of public lands.
The dangers of this model extend well beyond traditional financial market risks. GIX represents an incremental approach to bypass current regulatory and governance frameworks, making it easier for corporations to gain and maintain control over essential natural assets. Once approved, this model could become a Trojan horse, normalizing the financialization of ecosystems in other regulatory spaces and expanding the influence of foreign and domestic corporations over American resources. Public lands could become instruments of profit, where management decisions prioritize shareholder returns over environmental integrity and community needs.
Given these serious concerns, I urge the SEC to withdraw the GIX application. Allowing GIX to operate as a National Securities Exchange would mark a significant step towards the privatization of public resources and the consolidation of economic control under a narrow set of corporate entities. The SEC has a responsibility to ensure that financial markets serve the public interest. Approving GIX would do the opposite-it would institutionalize a corporate structure designed to consolidate the natural assets we all depend on.
This proposal is not merely a financial innovation; it is a profound shift in who has the right to govern, access, and benefit from natural resources in this country. The SEC should not endorse a system that so clearly serves the interests of a privileged few at the expense of the public and our natural heritage.
I respectfully urge the SEC to reject this application outright in order to preserve public access, stewardship, and protection of our nation's natural resources.