The CAQ appreciates the opportunity to share some high-level observations related to the Securities and Exchange Commission (SEC), Notice of Filing of Proposed Rule Change to Amend the NYSE Listed Company Manual to Adopt Listing Standards for Natural Asset Companies (Proposed Rule Change or Release). Our comments focus on the proposed requirements regarding 1) examination and attestation by independent reviewers and 2) corporate governance. Given the limited timeframe to evaluate the specifics of the reporting framework, and the fact that this will represent a new type of company with novel license arrangements, we believe additional questions could arise as entities begin to apply the Reporting Framework. We recommend the NYSE continue to monitor developments, including relating to the operability of the reporting and examination requirements, and propose changes to the Reporting Framework should the need arise. As noted in the proposal, such changes would be considered changes to the listing standards and thus would be subject to approval by the SEC.
Read the full comment letter here.