Who gains from saving nature
Ledger 1 : 33 — For each dollar financing nature-based solutions in 2023, about $33 financed activities harmful to nature. (UNEP)
Cases / Lobbying, PR and greenwashing · United States · 2021–2024

NYSE natural asset company proposal withdrawn

Nature's voice · report
No measurement of the harm done to me here is on record.
Did nature suffer? Not measured.
Not on record
  • The record does not name which of my species, waters, soils or forests were harmed.
What the record lacks: 4 none on record · 1 insufficient · 1 not measured · 2 disputed See the gaps

In 2021 the New York Stock Exchange and Intrinsic Exchange Group announced a new class of listed companies that would hold rights to the ecosystem services of natural areas. The Exchange withdrew its listing proposal on 17 January 2024, after a regulatory review and an objection from 25 state attorneys general.

US$125 trillion a year estimateValue of nature's ecosystem services cited in the 2021 announcement
A claim made in the announcement; the figure matches a 2014 estimate by Robert Costanza and co-authors. No natural asset company was ever listed.

Status As of October 2026: the NYSE withdrew its proposal on 17 January 2024; no natural asset company has been listed.

What?
A proposal to list companies that would hold the rights to the ecosystem services of natural areas, withdrawn before any listing. Cooley PubCo
Where?
United States: New York (exchange), Washington (SEC), and the states whose attorneys general objected. Cooley PubCo
When?
Announced 14 September 2021; SEC review opened December 2023; withdrawn 17 January 2024. TheCorporateCounsel
Who?
Gained
  • Intrinsic Exchange Group (planned, not realised) — Would have been entitled to a share of listing and trading revenue, according to a letter from a US member of Congress. Cooley PubCo
  • New York Stock Exchange (planned, not realised) — Minority shareholder in IEG with a board seat; would have listed the companies. Cooley PubCo
Lost
None on record
Harmed
None on record
Why?
The announcement cited ecosystem services worth US$125 trillion a year. The NYSE withdrew citing feedback from regulators and market participants; the attorneys general objected to land coming under private company control. Cooley PubCo
How?
The NYSE filed a listing proposal with the SEC, which opened a formal review; objections followed from 25 state attorneys general. Cooley PubCo
6 of 6 questions answered from the record

What happened

The record, in order.

On 14 September 2021 the New York Stock Exchange (NYSE) and Intrinsic Exchange Group (IEG) announced a new asset class, Natural Asset Companies (NACs). A NAC would hold the rights to the ecosystem services produced by an area of land, such as carbon capture, clean water and biodiversity, and would be listed and traded on the exchange. The announcement said the ecosystem services produced by nature were worth US$125 trillion a year.

IEG was a for-profit company. Its founding investors included the Inter-American Development Bank (IDB) and the Rockefeller Foundation. The NYSE took a minority stake in IEG and a seat on its board. According to a letter from a US member of Congress, IEG would have been entitled to a share of the listing and trading revenue of the NACs it helped list. IEG also wrote the accounting method, called the Ecological Performance Report, used to measure what a NAC held.

The NYSE submitted its listing proposal to the US Securities and Exchange Commission (SEC) in 2023. The SEC opened a formal review in December 2023, to decide whether to approve or disapprove it. On 9 January 2024 attorneys general of 25 states called on the SEC to reject the proposal. Idaho Attorney General Raul Labrador described NACs as a structure designed to take land out of productive uses in the name of environmentalism.

The NYSE withdrew the proposal on 17 January 2024, eight days after the attorneys general's letter. The reason it gave was feedback from regulators and market participants. No natural asset company was listed or traded.

  1. 202114 September: NYSE and IEG announce Natural Asset Companies and cite US$125 trillion a year in ecosystem services
  2. 2023NYSE submits its listing proposal to the SEC; one law firm dates the filing to September (reported, not confirmed)
  3. 2023December: the SEC opens a formal review to approve or disapprove the proposal
  4. 20249 January: attorneys general of 25 states call on the SEC to reject the proposal
  5. 202417 January: NYSE withdraws the proposal

What was said

Claims, in the words of those who made them.

Where accounts differ

Each party's account, side by side, with its source. The record does not settle these points; it shows them.

Should natural areas be held and traded through listed companies?
Company or project
NYSE and Intrinsic Exchange Group

Announced a new asset class, Natural Asset Companies, and cited ecosystem services worth US$125 trillion a year.

ESG Today
Government and regulators
Attorneys general of 25 US states

Called on the SEC to reject the proposal on 9 January 2024.

Cooley PubCo
Government and regulators
Raul Labrador, Idaho Attorney General

Described NACs as a structure designed to take land out of productive uses in the name of environmentalism.

Idaho Attorney General
Company or project
NYSE

Withdrew the proposal, citing feedback from regulators and market participants.

TheCorporateCounsel
Did the arrangement place the framework writer and the exchange on the same side of the revenue?
Government and regulators
A US member of Congress, in a letter

IEG would have been entitled to a share of the listing and trading revenue of the NACs it helped list.

Cooley PubCo
Company or project
Intrinsic Exchange Group

No response is on record.

How it looked

What was shown, beside what was recorded.

Shown

  • Ecosystem services worth US$125 trillion a year; a new asset class in which investment in nature would be listed on the exchange
    NYSE and Intrinsic Exchange Group, announcement of 14 September 2021 · ESG Today
  • The IDB and the Rockefeller Foundation named as founding investors of IEG
    Inter-American Development Bank, 2021 · Inter-American Development Bank

Recorded

  • The NYSE held a minority stake in IEG and a seat on its board.
    Cooley PubCo
  • According to a letter from a US member of Congress, IEG would have shared in the listing and trading revenue of the NACs it helped list.
    Cooley PubCo
  • The SEC opened a formal review in December 2023; attorneys general of 25 states asked the SEC to reject the proposal on 9 January 2024; the NYSE withdrew it on 17 January 2024.
    Cooley PubCo
  • The NYSE gave only feedback from regulators and market participants as its reason for withdrawing.
    Cooley PubCo

Who gained

Money that reached nature, beside money that stayed elsewhere.

Reached nature or the ground

Not published
No figure published.

Gained elsewhere

Not totalled
Currency: USD · Window: . All figures cover the same period. * Estimate built from cited figures.

Responses on record

  • nyse (17 January 2024): Withdrew the proposal on 17 January 2024, citing feedback from regulators and market participants. · Cooley PubCo
  • idaho-attorney-general (January 2024): Called on the SEC to reject the proposal and described NACs as a structure designed to take land out of productive uses in the name of environmentalism. · Idaho Attorney General

In court and with insurers

Every proceeding and every insurer decision on record.

Lawsuits and rulings

No court case on record. No court has ruled on this case.

Insurers

No insurer decision on record.

What nature saw

Outcomes measured on the ground, and nature's note.

Nature's report opens this page. Below: further outcomes measured on the ground.

Natural asset companies listed
None
The proposal was withdrawn on 17 January 2024 before any listing or trading
Ecosystem-services value claimed
US$125 trillion a year
Figure used in the 2021 announcement; a 2014 estimate by Costanza and co-authors

What we don't know

Undisclosed, unproven, untried: recorded as data.

Nature

  • Not measured Harm to nature: The record holds no measurement of harm to nature.

Accounts

  • Disputed Should natural areas be held and traded through listed companies?
  • Disputed Did the arrangement place the framework writer and the exchange on the same side of the revenue?
  • None on record Intrinsic Exchange Group: No response is on record.

Record

  • None on record The NYSE gave only feedback from regulators and market participants as its reason for withdrawing; no further explanation is on record.
  • None on record The date of the filing with the SEC: one law firm dated it to September 2023, which is reported but not confirmed.
  • Insufficient A pilot project in Costa Rica was reported at the time of the 2021 announcement but is not independently verified.
  • None on record IEG's own response to the objections is not on record.

Did the harm stop?

The proposal was withdrawn on 17 January 2024, before any natural asset company was listed.

Who paid?

No cost to nature or to named communities is recorded, because no natural asset company was listed.

Sources

Voices on record: — Company or project✓ Government and regulators— Courts✓ Press and investigations— Communities and civil society— Researchers

Government and regulators

Press and investigations

Connected cases

Related matters, and cases linked to this one through the same organisations, with the role each played in both.
Terms used on this page

Institutions

IDB
The Inter-American Development Bank.
SEC
The US Securities and Exchange Commission, which regulates securities markets and what companies tell investors.

Carbon and conservation finance

ESG
Environmental, social and governance criteria that investors and insurers use to screen companies and projects.

Bonds and banking

Guarantee
A commitment by a third party, often a development bank, to pay if the borrower does not.
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