Quick Overview of Themes in U.S. NAC Policy Timeline
- 2021–2022: NAC concept introduced and institutionalized through IEG and NYSE planning
- 2023: Proposed for NYSE listing; enters formal regulatory review
- 2024: Proposal withdrawn amid backlash; state and federal opposition mobilized
- 2025: Bipartisan policy debate intensifies; new legislative efforts attempt to ban or restrict NAC use in the U.S.
2021
Formation of the Intrinsic Exchange Group (IEG)
The Intrinsic Exchange Group, backed by the Inter-American Development Bank and Rockefeller Foundation, publicly launched the Natural Asset Company (NAC) model. The concept was based on monetizing ecosystem services and allowing nature to be structured as a productive, investable asset class.
2022
Initial NYSE-IEG Collaboration Announced
The New York Stock Exchange announced it would partner with IEG to create a new listing vehicle specifically for NACs, designed to represent ecological performance on capital markets. The announcement received quiet attention from the financial press but little public scrutiny at the time.
2023
September 27, 2023
NYSE Proposed Rule Change Filed
The NYSE submitted a proposed amendment to its Listed Company Manual to the Securities and Exchange Commission (SEC), introducing the legal framework for NAC listings. The proposal included new corporate structures, ecological performance rights, and ecological performance reports (EPRs) as listing requirements.
October 4, 2023
Federal Register Publication
The SEC published the proposed rule in the Federal Register, initiating a formal comment period. Critics began expressing concern that NACs represented an opaque financialization of nature with inadequate public oversight.
December 28, 2023
SEC Institutes Proceedings
The SEC opened official proceedings to determine whether to approve or disapprove the NYSE proposal, citing the need for additional public input and technical analysis. Pressure mounted from state legislators and private landowner coalitions.
2024
January 17, 2024
NYSE Withdraws NAC Rule Proposal
In response to growing political pressure and unresolved regulatory concerns, the NYSE voluntarily withdrew its proposal for listing Natural Asset Companies. This effectively halted NACs from moving forward within the U.S. stock exchange system.
January 17, 2024
H.R. 7006 Introduced (Rep. John Curtis, R-UT)
Title: To prohibit Natural Asset Companies from entering into any agreement with respect to land in the State of Utah or natural assets on or in such land
The bill aimed to block NAC-related contracts involving Utah state lands. It was referred to the House Committee on Natural Resources.
February 2024
State-Level Legislation Introduced in Utah and Wyoming
Multiple state legislatures proposed bills to prevent the transfer, lease, or management of state land or natural assets by entities resembling NACs. These bills cited sovereignty, transparency, and foreign ownership risks.
Spring–Summer 2024
Model Legislation Released by ALEC
Title: Natural Asset Company Prohibition Act
The American Legislative Exchange Council introduced model policy language for states to ban or limit the formation and influence of NACs. This was adopted in part by Wyoming and Texas legislatures by the end of 2024.
August 2024
Public Spotlight from Media and Advocacy
Mainstream media outlets including The New York Times and RealClearMarkets published investigative reports and editorials. Critics referred to NACs as "Wall Street’s quiet land grab" or the "privatization of public commons."
2025
February 2025
Federal Bill Introduced: Protecting American Sovereignty Act (Rep. Mark Green, R-TN & Rep. Harriet Hageman, R-WY)
Aimed to prevent the creation, funding, or listing of any Natural Asset Company under U.S. jurisdiction. The bill raised national security concerns about foreign control and asset speculation related to public and private land.
March 11, 2025
Senate Companion Bill Introduced: S. 941 (Sen. John R. Curtis, R-UT)
Title: A bill to prohibit Natural Asset Companies from entering into any agreement with respect to land or natural assets in Utah
Reinforced the objectives of H.R. 7006, reflecting state-level resistance to the concept of monetizing ecosystem rights through financial vehicles.
April 2025
Academic Pushback and Expert Recommendations
Multiple legal journals and environmental finance think tanks published policy briefs warning of market volatility, risk of greenwashing, and ethical concerns related to NAC governance. Scholars called for new financial ethics frameworks before NACs are allowed any re-entry into public markets.
Mid to Late 2025 (Expected)
SEC Review and Guidance Report
The SEC is expected to release an internal assessment summarizing public comments and the regulatory challenges associated with NACs. The report may influence future rule-making around environmental asset disclosure, ecological reporting, and ecosystem finance integration.