Real estate as a collateral on Harbor

Real Estate Asset COMDEX Integration and Token Minting

We propose integrating our real estate assets (can be reviewed at, into the COMDEX ecosystem. These assets have undergone thorough due diligence and are of high quality, with potencial of generating stable income streams. The integration will involve minting DAODISEO token on the COMDEX chain, backed by the combined value of the real estate assets.

Asset Backing and Title Transfer:

To ensure transparency and trust, we commit to providing the COMDEX/HARBOR community with full transparency and control over the real estate assets. This includes transferring all titles and rights associated with the assets. The COMDEX/HARBOR community will have complete governance authority over the real estate development project and its future direction.

The main benefit for COMDEX is an enhanced Asset-Backed Value: The integration of real-world assets, such as real estate, into the COMDEX DeFi ecosystem will significantly enhance the asset-backed value within the platform. Tokenizing tangible assets provides a strong foundation for sustainable growth, stability, and increased confidence among investors.

We would like to hear from the community, if such project fits into Community expectations and the overall direction of the platform.



Thank you for sharing this for discussion,
It would be beneficial to provide more specific details about how this integration can bring advantages to the Comdex platform, such as increased liquidity, diversification opportunities, or potential revenue streams.
And can you also provide insights into the timeline and roadmap for implementing the integration of real estate assets into the COMDEX ecosystem if the community is interested

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The real estate has not been build yet it seems?

So in principle the current collateral is purely a plot of ground?

Can you also share the due diligence and such the assets have undergone?


Conceptually very intriguing but I think we need more information. Dealing with RWA can be a game changer but there is so much nuance to it. There would have to be a massive element of due-diligence to ensure any RWA that we bring to Comdex chain is legitimate. Also who would be in-charge of the due-diligence? Outsourced or some DAO?

I’m interested but we definitely need some blueprint for how this will be pulled off

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Dear Community Members,

We would like to provide you with some additional context regarding our proposal for real estate asset integration and token minting. DAODISEO has been actively exploring the concept of real estate tokenization for over two years. In fact, this exploration led us to acquire real estate assets specifically for RE development purposes and further tokenization. We want to assure you that we have a full ownership of these assets (100% pure collateral). We have all required documentation to demonstrate this.

During this time, we made significant progress on the real estate development front. We have finalized architectural designs for the 340+ m2 villas, and we are currently in the process of obtaining necessary building permits in Greece (jurisdiction, is an important element of RE business from the legal stand point). Actually we have some achievements :slight_smile: in understanding the intentions of the legal structure and framework for RE tokenization in EU and Greece in particular due to our clear interest for years to come. As proud owners of four plots (all of them over 4.000 2m), we are excited about the potential value of these project developments as well as its potential digital representation on blockchain platform. We believe that there is a value to be unlocked there. We would like to continue this discussion. We already took a decision to use COSMOS ecosystem as our tech platform.

It’s worth noting that each villa’s development cost is estimated to be less than $1 million, while the fair market price of the completed houses is expected to surpass $2 million each. So the total value locked over the next 3 years could be of 8M$. We believe that given the nature of BTC cycles, to which any crypto will be exposed (also COMDEX), there is a growing need for easy and quick exchange of RE Assets with some other form of crypto liquidity in both directions. Also there are real actors on the market looking for both tokenizing their assets and adding liquidity to such market. From what we could research, the main barriers are related to the perception that there is no legal framework for such market yet. The real fact is that it is mostly lack of understanding. The topic of Unregistered Securities is very hot these days and it will continue to be in the future.

We understand your concerns about due diligence and the execution of such a project. Rest assured, we have conducted thorough due diligence on the properties, their viability, and their potential to generate stable income streams. We are committed to transparency and will provide detailed insights into our due diligence process and findings as we move forward within the discussion and complete the proposal.


We would like to engage in the conversation regarding the details and the advantages of the integration with COMDEX provided the community would consider to be engaged in such discussion. We want to be humble.

We are are crypto enthusiastic believers of BTC end DiFi for years now (5+), but we also understand very well a Real Estate business, the reason being, many of the community team members are from RE business. Other members are mainly Freelance Business Consultants and IT professionals working with contracts with different corporations. Typically in our work we do Business Process Design and Run deployments for Business Transformation projects.

DAODISEO would like to see DIFI build on top of very solid vaults, with assets that can be trusted. We believe that Real Estate has a capacity to generate that level of trust, that chains needs to attract new real users. RE does that by leveraging its nature of being long term investment in general, not susceptible to bank runs, generating predictable income to the project, so it would be easier to overcome cyclical character of BTC. Those upcoming years will be very bumpy :slight_smile:

DAODISEO wanted a solution that responds to some basic and real needs of the RE markets. Liquidity pools for people who are running RE development project, so they can calculate APY of each investment as well as place were user could exchange their RE assets into crypto, as well as using it as a collateral in DeFi products. We believe in product that give the user a healthy exposure to real estate asset that are tokenized but fully protected and safe in vault. We are are also in the position to provide necessary initial liquidity.

From reading all the inputs from the community in general, we see different opinions regarding direction of the COMEDEX chain. Having said that , we trust that the community will be able to overcome those challenges. We want to be positively oriented , and eventually contribute and never rest.

We appreciate your inquiry about the current status of the real estate assets and the due diligence process. While the properties are not fully developed yet, we assure you that they have undergone extensive due diligence. This includes assessments of their viability and potential for generating stable income streams. We will provide a detailed overview of the due diligence process and findings in our revised proposal to address your concerns adequately. The project is reasonable in Pilot + 2nd Phase with additional 3 villas. All could be done in 2 years from the moment of construction begin.

Thank you for finding our proposal conceptually intriguing. We acknowledge the significance of conducting comprehensive due diligence when dealing with real-world assets. To ensure legitimacy, we propose a robust due diligence process involving a combination of outsourced expertise and community involvement. We will outline the specifics of this process, including the roles of external experts and community-based governance, in our revised proposal. Furthermore, we will provide a detailed blueprint that outlines the steps required to successfully execute the integration real estate assets into the COMDEX ecosystem.

We appreciate your engagement and look forward to incorporating your feedback and suggestions into our revised proposal. Your contributions are vital in shaping the future direction of this project. Should you have any additional questions or concerns, please don’t hesitate to reach out. Together, we can build a stronger and more sustainable COMDEX ecosystem.

Best regards,

Regenerate response

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I am looking forward to the outlining of the process in the revised proposal. Just put it online when you have it, we will be here :slight_smile:

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Dear Community Members,

We are excited to continue conversation regarding our proposal, which revolves around the integration of real estate assets on COMDEX. Our belief in the transformative power of blockchain technology and its potential to reshape the financial landscape is backed by three key long term investment theses:

  1. “We believe that the FIAT system dominated by EUR/$ will morph into a more granular architecture while deliberately generating social pain, as proven over the recent years.”

  2. “In such context, a trusted financial interface service between FIAT-based Real Estate (RE) business and crypto assets will be demanded.”

  3. “We also believe that BTC will continue to influence the total crypto market capitalization via its 4-year cycles. Convenient swaps between RE & Crypto Assets in both directions represent an attractive long term financial solution for crypto volatility during each cycle.”

Building on these investment theses, and after observing RE tokenization attempts by some projects, we identified some design pillars, that we believe could work and fit at the same time into continuously evolving legal paradigma. This proposal encompasses 5 key elements:

  1. Legal

Attachment to the FIAT World, via SPV (Legal Entity) that own RE assets, governed via on-chain decision-making process related to Physical Assets & Day-to-Day Management - COMDEX seats/role, DAODISEO seats/role, HARBOR seats/role (Board of Directors). Listing & Operating new SPVs become a potential source of revenue for the network. We propose the establishment of a Special Purpose Vehicle (SPV) as a Legal Entity governed through an on-chain decision-making process. This SPV will be constituted in the jurisdiction with proximity to the Real Estate Assets. It will be managed by nominees from COMDEX, HARBOR, and DAODISEO. The SPV will play a crucial role in developing technologically advanced Liquid RE Assets. It will invest their benefits from RE into Technology and Crypto Assets, thereby fostering growth and innovation within the ecosystem. Moreover, the SPV will be responsible for maintaining sound and transparent due diligence data, which will be leveraged by the community for white-listing of assets and approval of parameters for the HARBOR vault. The SPV will also manage the vault using multisig or similar technologies, ensuring the security and integrity of the assets.

  1. Oracles & Price Discovery.

RE Agents would act as RE Oracles and facilitate the due diligence and legal processes for SPV safe buying of Real Estate Assets. DAODISEO will collaborate with RE agents to develop their role as “Oracle” for price discovery mechanisms implemented on their websites. This concept involves sending a price fit to the blockchain each time the agent’s website displays our widget. Once ready for pilot, agents will execute marketing campaigns with potential FIAT buyers, making our Real Estate products more accessible and attractive to a broader audience. This will enable customers to be exposed to both Real Estate and crypto assets, providing a seamless and convenient way to balance their investment portfolios. We see a possibility to integrate with HARBOR auctions.

  1. RE Assets Whitelisting process / COMMODO Risk Assessment & HARBOR Vaults Management / ODIS Minting.

We recognize that proper asset acceptance and due diligence processes are crucial for the RWA integration. For those less familiarized with RE, standard steps for RE due diligence are widely accepted by the market. We should just follow those steps. Therefore, we propose a robust risk assessment process , executed via Governance on chain and supervised by COMMODO Risk Management Process (your web site claims that you have one). We understand that we could easily agree what are the steps after that, to whitelist new Real Estate assets based on their viability and potential. The HARBOR vaults that holds given RE asset will be carefully managed, ensuring that only trusted assets are accepted and included. ODIS will be minted as a representation of the tokenized Real Estate assets, providing users with secure and transparent way to access and trade these assets within the COMDEX ecosystem.

Our interaction with Traditional Banking sector, opened possibilities for financing of pilot project. This way, we could also bring liquidity from the FIAT World on chain, which is benefiting COMDEX and Crypto Industry in general.

  1. Blockchain Development of DAODISEO “RE branch of COMDEX”, is financed via RE SPVs investments. Each listed SPV has a mandate to invest agreed portion of their benefits back into blockchain technology. The long term vision is that SPVs will manage their assets fully on chain. Well understood and transparent RE assets provide additional level of trust, while dealing with DEFI protocols.

  2. Initial liquidity pool. We are open for discussion. We would like to know what Community believes is fair in the context of the above.

Thanks for your update!

It continues to hinge on the due diligence done on the RE though. What are the guarantees these are where and what they are? How can we trust the price discovery (and update to the price for that matter)?

That is one of the very key elements if you would like to bring RE on the blockchain as an investment vehicle. Someone has to guarantee that that specific RE is only offered once and only on the Comdex chain and not on multiple markets. Because in the latter it becomes a derivative where the collateral is not fully backing the derivative anymore.

Dear COMDEX Community,

We are excited to continue a meaningful discussion regarding the integration of real-world assets (RWAs) into the COMDEX ecosystem. As a community-driven initiative, your input and insights are crucial in bridging the gap between traditional assets and the crypto world. It’s important to underscore that in our opinion the survival of blockchain projects hinge on their deep connection to the reality of traditional business operations. If we all want to see a blockchain bright future, we can’t work in isolation from the real world.

We would like to also stress, that in our professional day to day role as business consultants, we have consistently witnessed that sustainable business success arises from a profound understanding of how traditional businesses operate (in this case RE development). Therefore for crypto projects, when it comes to designing technological solutions, we believe that emulates real-world business operations, is the key to surviving next crypto cycle. In order to understand how RE due diligence process could work on chain, we need to first familiarize out self with the common RE development process itself and way it works in real life (See link below. Reflect if possible on each step in the process.)

Your concern about the guarantees of the real-world assets’ authenticity and specifications is absolutely valid. Our vision is to transform this real-world development process into an on-chain governance mechanism that encompasses every step (see link to the process above), from forming the initial concept to the final realization of a project. The blockchain’s immutability and transparency empower us to methodically execute each phase and record outcomes, creating an auditable trail of the entire journey (including all documents that could be attached on chain). This approach ensures accountability and engenders trust, as stakeholders and interested parties can track and verify the development’s progress in a decentralized and verifiable manner.

Regarding the risk of the same Real Estate (RE) assets being minted by the Special Purpose Vehicle (SPV) on multiple blockchain chains; It would indeed be imprudent for the asset owners. This is one of the examples of how real world works (there are potential legal consequences). Consequently, it is highly unlikely that such a course of action would be pursued by the SPV Board of Directors. The primary objective of the SPV is to effectively manage its transactions through blockchain technology, seeking to maximize the utilization of this technology across various avenues. This strategic approach serves as the foundation for generating sustainable value within the SPV framework. Accounting books of SPVs must be open to the community.

Furthermore, the Board of Directors of the SPV consists of well-known individuals who have been nominated to fulfill their responsibilities with the utmost integrity and diligence. Any actions that deviate from these principles and venture into fraudulent behaviors would undoubtedly be subject to scrutiny and potential legal consequences. In essence, the SPV’s approach aligns with the principles of transparency, legitimacy, and value creation, thereby fostering an environment of trust and credibility within the ecosystem.

In the context of integrating Real Estate (RE) assets into any blockchain ecosystem, it’s crucial to acknowledge the ongoing global trend toward each country developing digital registries of real estate assets. This movement signifies a pivotal shift in the RE industry, with many countries, including Greece, recognizing the significance of transparent and accessible digital records for property ownership, transactions, and financing. Once those registries are fully deployed and operational, we definitely see a need to connect to them.

P.S. We would also like to discuss price discovery part, but let’s try to decide first on the feasibility of executing RE development process by levering on chain governance. We will be waiting for your feedback.

Best regards

Can you elaborate a bit on the guidelines this process will be working under (laws, regulations, etc.) and which legal bodies are involved (notary, etc.)

Furthermore, in which countries will the RE be located? I’ve read Greece, but did you also dive into the full European set of guidelines?

"Hello Comdex Community,

We appreciate your questions as we collectively explore the integration of real-world assets into the blockchain ecosystem.

Addressing the critical topic of legal guidelines and regulatory frameworks, we firmly acknowledge the imperative nature of operating within a robust and well-defined legal structure. Our proposal is aligned with the EU Markets in Crypto Assets (MICA) regulations, a comprehensive framework that encompasses all European Union member states. It’s important to note that we specifically mentioned Greece due to our existing real estate assets in the country and our established relationships with professionals actively involved in advising on MICA compliance within Greece.

Diverse jurisdictions are currently at varying stages of crypto regulatory development. However, the introduction of MICA regulations signifies a harmonized approach across EU member states. This provides our initiative with a broad geographical scope while setting a precedent for integrating the worlds of traditional assets and blockchain technology.

Link to MICA regulations: Markets in Crypto-Assets Regulation (MiCA).

On the topic of different actors potentially involved; We firmly believe that tackling the integration of real estate (RE) into the crypto world requires a comprehensive perspective that draws from the best practices of the real world. A key aspect of this integration lies in the development and financing processes followed by Special Purpose Vehicles (SPVs) engaged in real estate projects. These SPVs adhere to well established methodologies for developing and funding projects, ensuring transparency, risk mitigation, and alignment with regulatory frameworks. The goal is to replicate these robust processes on the blockchain to maintain the same level of trust, while enhancing efficiency and accessibility. In the real world, investors will not provide financing unless there is proof that the project has undergone the process outlined above.

To comprehend how RE Limited Entities (SPV businesses that hold specific RE assets) approach development in the real world, we also need to become acquainted with the concept of the ‘capital stack,’ which plays a pivotal role in shaping the financial structure of a project. Visualize it as a stack of building blocks, with each block representing a distinct funding source that contributes to the overall financing of the project:

Level 1. At the foundation of the capital stack, you’ll find secure and stable funding sources, typically provided by banks or traditional lenders. These sources form the solid base upon which the project is built.

Level 2. Moving upward, the stack includes equity investments from individuals or groups seeking ownership in the project—these are like the middle layers of the stack.

Level 3. Towards the top of the stack, you’ll encounter more flexible and higher-risk funding sources, such as mezzanine loans or crowdfunding from the general public. These sources, resembling the top blocks of the stack, provide additional support to the project’s financial structure.

In essence, the capital stack is a composition of diverse funding types that collaboratively contribute to a real estate project’s financing. Each source of funds plays a role in shaping the project’s success and ensuring its viability. Each of those levels represent a potential opportunity for crypto integration.

Link to know more about capital stack: Everything You Need to Know About the Capital Stack - Feldman Equities

Capital stack level 1 above:

Given the above, we should ask our self what make sense at this stage of DEFI maturity. For example, regarding level 1 of capital stack above; traditionally this would be executed either via FIAT bank or securitization process (also very common). Issuing securities of course imply that SPV need to also follow security law (not too complex up to 5M$). We explored already this option and it is indeed one of the ways to go, specially for those whose only goal is to develop RE. Having said that, we assume that we are after bigger fish here. Also, worth to mention that typically FIAT investors that buy these type of securities only expects return of capital and they are not taking part of the business (a little bit like people that provide liquidity expecting APY). Please notice that the current standard in the EU market is about 10% (each project is different). Without getting into details now, we could brain storm few ideas in this area:

  1. Long term, and thinking about future of DEFI, would it make sense to manage such loans via crypto validator nodes and its delegators ? (in this scenario SPVs run a nodes as a technology that is useful for the business). There are potentially many SPVs to achieve decentralization in such scenario.

  2. Is it feasible to integrate such concept into existing blockchain like COMDEX, or on the contrary is impossible, and we would need an independent DAO with new governance token, and maybe even discreet cosmos chain connected with ecosystem via IBC ?

  3. Is there a value for existing chains like COMDEX, from building DEFI based on real assets, that indeed are perceived as valuable by general public ? Some how we believe in crypto projects that are able to develop products for crypto but also for non-crypto users to be successful.

Capital stack level 2 above:

We envision the possibility of issuing tokens that mirror the various tiers of this capital stack. As we ascend the stack, it encompasses equity investments (shares in SPV) originating from individuals or collectives aiming to gain ownership in the project. These equity investments can be likened to the middle layers of the stack. We could definitely issue token with quantity and value that correspond to the fair market value of the real estate at the point of white listing the asset. Please remember that decision making process should be executed on chain (the process we posted in the previous communication).

Similar approach could be followed with subsequent level of capital stack.

Another brain storming idea: Would it be possible to offer a house to buy (e.g. luxury villa that has a price of let’s say 2M$) that come directly with crypto credit line ? We would need to tokenize that credit line of course.

Please notice that it is very much all about transparency of SPV financials and making them open, for traditional and crypto investors. Crypto project that accept RE asset face a similar challenges as traditional lenders.

Let’s continue this discussion …

The more time passes, the more interesting the idea is.

I am kinda curious though if we can get this started as a very small scale experiment.
It would bring Comdex back to the original USP of having commodities on chain for people to profit from. It would surely make Comdex different and unique again, which I very much would like to see.

Is there an option for a small experiment?

Dear Comdex Community,

Your curiosity has ignited a spark that we’re eager to fuel. Suddenly we started imagining COMDEX as an international Trust that owns RWA assets around the world via SPVs. At the same time knowing about those assets everything, as they went trough on-chain Due Diligence Process, while at the same time SPVs (COMDEX representation in real world and financial HUB with FIAT system) are financially engaged in blockchain generating transactional flow. We guess this was the original idea, and it is still possible. It would likely bring benefits long term :slight_smile: .

Now, we’ve been listening closely to your musings about a small-scale experiment. Guess what? We couldn’t agree more. Please remember, we are business consultants use to deploy technology. Therefore we see many obstacles and questions to be answered. But our approach aligns perfectly with your notion of “step by step thinking”. Even though we truly believe that the concept has a huge potential, we still need to prove it. It is very positive that we now both see this potential and we could likely both foresee what a such turn might add in terms of credibility to COMDEX.

Such audacious journey means Comdex validators could evolve from crypto custodians to stewards of tangible assets, empowering the community to invest in and benefit from Real World Assets like never before. They could also bring a connection with Real World and their FIAT system. We tend to think about this idea very positively, as we could potentially even leverage FIAT financing were a lot of money seats. We could potentially bring some of this liquidity to COMDEX. We could also promote creation of SPVs that hold commodities.

This experiment is about embarking on a collaborative exploration. We need to showcase the value we can bring together to the Comdex chain while respecting the community’s concerns. It’s like taking a test drive before committing to the epic road trip. :red_car::dash: We are open to discuss and agree on the road map, steps and details of the design, always keeping simplicity at the forefront. Our goal is to create a simple solution where standard blockchain capacity is providing quick wins, and that leverages the utility of the Comdex token with it’s DEFI capabilities, minimizing complexity (easy to understand) while maximizing its real-world impact.

Designing the merger of the first Special Purpose Vehicle (SPV) that possesses Real World Assets (RWA) into the Comdex ecosystem should be a well-thought-out process that aligns with the long-term vision of the community. We are open for your suggestions regarding overall approach for the “Experiment” that you mentioned. Meanwhile, here are few areas that might be part of the exercise:

1. Governance Framework:

  • As per past conversation, we would need to establish a governance framework specifically tailored to the integration of RWA SPVs into the Comdex ecosystem. I think this part is conceptually well covered by our RE Development Process steps. We would likely need some kind of UI that makes due diligence process on-chain user friendly. We think that the key aspect could be to link governance of each step with the concept of unlocking of ODIS token that represent the total value of all SPVs debt issued from capital stack 1 against whitelisted assets as a collateral (funds that are at the foundation of the capital stack of the SPVs, and are part of the long term strategy toward buying progressively more and more new RE assets, therefore by nature of it secure and stable). By implementing it, The Community has a control upon the process of issuing such debt (acting as a lender to SPVs). This debt become SPV liability and stable stream of income was generated for COMDEX as a whole. Community is now building their presence within the Real World and starts becoming credible partner for traditional financing. We believe that the possibility to “suck liquidity” from FIAT world into COMDEX should not be forgotten.

2. Community Buy-In:

  • We hope that we would be able to progressively mobilize Comdex community to be actively involved in the decision-making process regarding the merger of RE Assets. We would like to hold open discussions, forums, and voting rounds to gauge community sentiment and consensus on the integration of RWAs. The level of interest will be crucial, as this would eventually proof that concept has a traction on COMDEX. We believe that DEFI community with presence in Real World could actually make a difference.

3. 1st SPV and Scalability discussion:

  • We believe it would recommendable, to set clear criteria for selecting the SPVs that are in line with the long term Community Strategy to possess RWA assets. Only business with (USP), Something like “Unique RE around the world, with significant potential for long term appreciation, that wants to invest in and build on blockchain”, would be accepted for due diligence during the initial phase of the road map. We need to consider factors such as the type of RWA, jurisdiction, asset value, and alignment with the community’s goals. In this area is all about uniqueness, positive marketing and potential for growing in value with time.

4. Regulatory Compliance:

  • We need to ensure that the selected SPV complies with all relevant regulatory requirements in its jurisdiction. This includes legal documentation, licensing, and adherence to local real estate laws. In traditional world this is integrated in due diligence process. We might want to follow the same concept. We are currently covering EU area, but we assume that other jurisdictions could be explored as we move forward.

5. Asset Evaluation:

  • Conducting a comprehensive evaluation of the RWA assets held by the SPV is a big part of how community is adding value. SPV would be required to provide an input, prepare and facilitate the community assessments of asset quality, value, income potential, and associated risks. In traditional world this is integrated in due diligence process. We might want to follow the same concept. The interesting topics in this area are those related to the progressive appreciation of the assets and how this is recognized in SPV books as well as on the blockchain (SPV open ledger).

6. Smart Contracts:

  • Develop and deploy smart contracts that govern the relationship between the SPV and the Comdex ecosystem. These contracts should outline the rights and responsibilities of both parties, including profit-sharing, fees, and dispute resolution mechanisms. Some of this “relationship set-up” could be addressed by the node it self (e.g. % of Commission could be understood as a margin paid to SPV for not only been a validator, but also a crypto custodian to stewards of tangible assets, empowering the community to invest in and benefit from Real World Assets like never before). Validator is also paying back delegators, but the huge difference is that now, it is not only from system inflation, but also some portion of SPV benefits could be leveraged for incentives. In the other hand, some workflow part of the process might need to be developed (e.g. Stack 1 long term debt waves when issued via due diligence process could be then send for final acceptance by the SPV board of directors multi-sig wallet). We would also need to figure out how to implement and maintain healthy ODIS/CMDX liquidity pool.

7. Community Representation:

  • We would need to make sure that the SPV is viewed as a representative of the Comdex community in the real-world asset space. This representation involves advocating for the community’s interests, protecting assets, and transparently reporting on asset performance. At some point of the due diligence process we should issue Stack 2 equities that represent the ownership on the SPV shares. Ideally there would be healthy representation of Community Owners.

8. Integration with Existing Validators:

  • Integrate the SPV and its assets into the existing validator network. It would be interesting to know what population of validators would transition to validate transactions related to RWA assets and participate in governance decisions related to these assets.

9. Risk Management:

  • Implement robust risk management strategies to mitigate the potential risks associated with RWAs. This includes strategies for asset diversification, insurance, and contingency plans for unforeseen events. In traditional world this is integrated in due diligence process. Some of those requirements are shorter and other longer terms in the due diligence cycle. We might want to follow the same concept.

10. Transparency and Reporting: - Mandate regular updates and reporting from the SPV to the Comdex community. This should include financial reports, asset performance updates, and compliance documentation. This process might be established and agreed during due diligence. We might want to establish a mechanism for periodic reviews and audits of the SPV’s performance and adherence to the community’s goals and principles. Adjust the strategy as needed based on these reviews.

11 Empowering Long-Term Real-World Asset (RWA) Accumulation: - We are firm believers in the transformative potential of this strategy. Our aim could be to champion the ownership of RWAs as a community and pave the way for a groundbreaking shift in thinking about COMDEX. We propose the development of a comprehensive long-term strategy dedicated to accumulating RWA assets within the Comdex ecosystem. This strategy will provide clear objectives, realistic timelines, and effective methods for incrementally expanding the footprint of RWAs. We believe that in ideal world, we would aim to balance demand during the grow period with the amount of RE assets on chain, knowing that RE assets cycle is far longer than crypto one. We could manage RE pipeline accordingly and on the way to leverage possibilities from positive and attractive marketing of Technology Advanced RE Assets.

12. Community Empowerment: - Ensure that the Comdex community has the power to vote on critical decisions related to RWAs during Due Diligence on chain process. The ideal scenario is that with time, community adopt long term RWA accumulation strategy as a “the path to go” for credibility, growth and success during the crypto hype periods.

We hope, that the pilot merger of the first RWA SPV could be seen as a significant step toward revolutionizing the Comdex ecosystem by expanding its asset portfolio beyond cryptocurrencies. Having said that, it would need to be driven by a clear long-term vision, strong governance, community involvement, and a commitment to transparency and compliance with regulations. This approach can help build trust within the community and establish a solid foundation for the integration of real-world assets into the Comdex ecosystem.

Best regards

Sounds good and quite elaborate.

Have you checked whether a SPV can be risky in terms of being classified as a security?

Do you already have a time plan for the next steps to take? Do you want some kind of community get-togethers to make decisions or gather input? Or time-wise plans when certain steps have to be taken?

Hi Community :slight_smile:

We appreciate your positive response and your valuable questions. Addressing your inquiries first:

Classification as a Security: We believe that the following passage from the MICA law is protecting us, as long as we promote decentralization, and keep SPV granularity under approx. 5M$ each.

I would say that it is very reasonable size from EU law perspective and for COMDEX too. Please see attached screen shot from MICA Law:

Time Plan for Next Steps: As we delve into the exciting prospect of integrating Special Purpose Vehicles (SPVs) into the Comdex ecosystem, we find ourselves at a remarkable juncture. The impending timeline set by the Markets in Crypto-Assets Regulation (MICA), with the approval of Title III and IV slated for June 2024, presents us with a unique and time-sensitive opportunity.:

Under the provisions of MICA, we observe that SPVs can operate without the extensive regulatory requirements if certain conditions are met. One such condition is that over a 12-month period, the average outstanding value of the asset-referenced token issued by an issuer must not exceed EUR 5,000,000, or the equivalent amount in another official currency. Moreover, the issuer should not be linked to a network of other exempt issuers.

This specific condition aligns seamlessly with our vision. It opens the door for us to birth SPVs within the Comdex ecosystem, capitalizing on the simplified regulatory framework envisioned by MICA. By staying below the EUR 5,000,000 threshold, we not only streamline our journey but also pave the way for agile and efficient SPV operation.

This opportunity is akin to setting sail on uncharted waters. It allows Comdex to become a pioneer in harnessing the potential of Real Commodities SPVs with it’s unique “Due Diligence on Chain”, unleashing their capabilities to empower our community. As we navigate through this regulatory landscape, we could poised to revolutionize the Comdex ecosystem.

Thinking about what would be the MVP for such Pilot:

  1. Independent Node running in name of the first SPV. What is the community recommendation for us ? Should we use white labeled outsourced node, or we should do it differently ? Do you have any preferences from community perspective ? I would also like to recognize that we noticed that you Leonoors Crypto, you are running successful node. What would be your own recommendation for the group ? I guess we need to think about management of this node already via multi-sig wallet that is in hands of BOARD of SPV. What is your recommendation as a solution ?

  2. We would need a great design for RE Development UI , connected to on-chain governance on COMDEX. What is the best approach ? The concept revolves around creating a seamless and transparent due diligence process for real estate development projects within the Comdex ecosystem (following generic RE development process adapted to our needs). It aims to ensure that the community has control over the financing of these projects while safeguarding their interests.

Key Features & some early questions that you might want to help with:

  1. User-Friendly Dashboard:

The SPV NODE web UI should have an intuitive COMDEX node dashboard that allows users to easily understand NODE DATA and relay them to the SPV native assets that are minted (e.g. debt or equities). Among SPV assets we can see CMDX holdings as well as all other node parameters, but also there are appropriate links to navigate through different stages of the RE development process related to the assets (the same due diligence process leveraged by Community). Users can track project progress, approvals, and financial details provided directly by the node. Decision to stake might come from that angle.

  1. Blockchain Integration:

We need to keep RE project-related data in a wide sense. Could we store them together with NODE / VAULT ? Do we have a standard place to keep Project Data tied to the Node or Vault ?

Due Diligence approvals and status of due diligence elements (checklist). We understand that this would work via COMDEX governance, but can we easily access these type of on-chain data and present them on the UI ? What are the current best technics to access on-chain data via query, in order to fetch dispersed data across subsequent blocks data from COSMOS type blockchain ?

Allocation of the waves of cleared assets (Capital Stack 1) to the ODIS holders.

  1. Capital Stack 1 Debt:

This represents the foundational funding for real estate projects. From the SPV Node UI Delegators can monitor “SPV capital stack 1 debt” issued by SPV in the context of the total ODIS accruals issued by the system in form of ODIS fungible token that gives access to white listed assets. The SPV debt is issued by given SPVs as non-fungible in nature token (pegged to the unique asset) that consume ODIS balance once authorized by due diligence process. In this scenario fungible ODIS accrual tokens are just a vehicle to manage an excess of interest by the public in form of staking CMDX to our node. The ODIS accruals could be automatically allocated to whitelisted assets following FIFO to people who are staking with the SPV node. The CUPONS of these contracts could follow FIFO chronological settlement calendars and could be paid by the SPV Node accordingly to the user wallet who owned ODIS (smart contract).

We would likely require contract running on chain to protect 5M$ compliance requirement:

*"Over a period of 12 months, calculated at the end of each calendar day, the average outstanding value of the ODIS asset-referenced tokens (debt capital stack 1 + value of equities (not minted yet at genesis) can never exceeds 5M EUR, or the equivalent amount in another official currency (we would likely select $)" .

We could start minting of ODIS as new delegators are staking CMDX on this node. Is this something that would need to be approved as a Protocol upgrade ? How this works ?). It will be likely fair to assume that staking on this particular node has a significance of promoting the project and allowing ODIS to be issued (locked) in the first place. We need to introduce that rule of 5M$.

We think we could easily design minting formula that slows down minting as we are approaching the limits.

  1. Unlocking Mechanism: The unlocking of ODIS-Assets-Referenced tokens (non-fungible) is directly tied to on-chain governance approvals. For example, when the community reaches a consensus to approve a specific chunk of development project, a portion of ODIS coins held by people can be now swap for Assets-Referenced coins.

Community Get-Togethers: In line with our commitment to transparency and inclusivity, organizing community get-togethers or virtual meetings is an excellent idea. We would start simple, let’s make 1h brain storming session to discuss what is possible, what do you think ? This could evolve in 1h weekly working session with few individuals that feels it is good idea and want to participate. We could decide to record the sessions to use it for future material for marketing. These gatherings can serve as platforms for detailed discussions, brainstorming, and sharing insights. They could be organized in topics as suggested on the list. This would enable us to collectively address concerns, fine-tune strategies, and ensure that all stakeholders are informed and engaged throughout the process. We believe that community involvement is vital for the success of this endeavor, and such gatherings can facilitate meaningful participation.

Time-Wise Plans: Time management is crucial, especially when dealing with a multifaceted project like this one. We intend to develop with you a detailed project plan outlining key milestones, deadlines, and dependencies for each phase. This will ensure that everyone involved, including the Comdex community, validators, and SPVs, is aware of what needs to be accomplished and by when. Flexibility will be built into the plan to adapt to changing circumstances and regulatory developments.

Your questions and feedback are invaluable. Please be so kind and provide your best answers to few questions presented above. Please let us also know if we could organize 1h Zoom Kick-Off session.

We look forward to further discussions and planning.

Best regards,

A couple of questions rising from this:

  • why would you need to run a node? There are a ton of endpoints available already from willing validators if you need connection to the chain. I read that you want to give delegators ODIS and only for them the rewards are applicable. If you really want to create value you should make it Comdex wide. I would rather see a grant request than something which is validator-specific.
  • regarding connecting to comdex governance; just make sure you build it on the Comdex chain with maybe parameters which are governance influenced. Or it needs to be more like a DAO structure (not available on Comdex yet as far as I know)
  • do you already have plans to integrate on the testnet? Before actually struggling with a lot of stuff it might be useful to do a very very MVP to see if you can mint with the chain and do the things you want before you put a lot time in details.
  • with respect to data storage: there is no choice to tie it to a node or validator. It is the whole point of blockchain to distribute data. If it would be able to make it node/validator specific, then it becomes a single-point database again which doesn’t make sense.

Hi Community :slight_smile:

Certainly, we share the vision of offering Real World Assets (RWA) opportunities to the entire Comdex community. Our ultimate goal is to provide value that extends to every participant within the ecosystem. We understand and appreciate the importance of creating a solution that is accessible, transparent, and beneficial for all.

You mentioned, a “Grant” path: That would be lovely. Maybe such a grant should go to ALL active participants of RWA Due Diligence process ? I am sure we will have more ideas for this possibility.

In response to your input, let’s explore how we can ensure that this RWA initiative truly becomes a Comdex-wide endeavor, offering valuable opportunities to every community member. Nevertheless, before we move to that ideal end-state, let’s try to fully understand a “Real World” perspective of people that are owners of RWA and eventually wants to tokenize them. We need to be able to incentivize RWA Owners and convince them to do it with COMDEX (more assets is better, and this should be long term community goal to make COMDEX great again). Otherwise we will not have assets to tokenize at all in a first place. We need to find a trade-off solution, if we want to bring RWA on chain.

So, here is the RWA asset owner perspective (by the way, don’t forget that often those people are new to crypto and are looking at the entire industry with reservations). Certainly from helicopter view, running a node has several compelling advantages, all rooted in the concept of credibility and trust:

  1. Credibility and Trust: In the realm of Real World Assets (RWA) but also On-line, credibility is paramount. Running a node signals a commitment to transparency, responsible operations, and regulatory compliance. This commitment instills trust not only within the Comdex community but also among external stakeholders, including regulators, investors, and partners. I am assuming that you Leonoors Crypto, since you are running successful node, you have a reasons for doing so. It would be great to join efforts with someone who has extensive experience in running node responsibly. We believe that innovative aspects of this proposal is a possibility of designing very close integration between Validators (a backbone that sustain the network) and Real World represented by SPVs. Personally, I am not in favor of big DATA processing organizations that are running nodes for chains with no personal attachments to the network and with selfish desire to drain the chain in mind only.

  2. Security Assurance: A dedicated node enhances the security of asset-related data and transactions. By controlling their node, SPVs can show to the external world that they protect sensitive financial information, ensuring that it remains tamper-proof. This level of data security fosters trust and confidence among stakeholders, a vital aspect of RWA operations.

  3. Transparency Showcase: SPVs can leverage their node to showcase asset holdings, financial records (CMDX holdings, Liquid ODIS holdings and RWA-referenced assets minted). This could be complemented with due diligence processes information obtained from on-chain transactions. This transparency not only complies with emerging regulations but also fosters trust among potential investors and partners.

  4. Operational Control: Running a node grants SPVs greater control over their blockchain operations. This control enables them to tailor their operations to meet the specific needs of RWA management, ensuring efficient and secure processes.

Key aspect of the process is to incentivize decentralization, and how RWA assets could end up in hands of COMDEX community and users following realistic, ordered and logical steps:

The fact that 1st liquid ODIS wave of fungible tokens issued to the system will end up in hands of delegators at the starting point, is actually a quite logical step (this token also carry stability element of the RWA protocol). Let’s assume that you want a several people (as many as possible) to share 1 big asset (Let’s say a final value of RWA in some years is estimated in 10M$). It will be far easier to convince them to do it via node delegation, than with any other App that you can put on top of the platform. By doing so, they show their commitment not only to invest in Real Estate, but to invest in a modern version of RE on COMDEX, that is fully integrated with the network and functioning in line with delegation protocol that provides sufficient level of confidence.

Meanwhile within reasonable time frame, some people from COMDEX community and those new that will join if we do it “right”, enjoy Due Diligence process on chain. We need to think, how we could compensate them for doing so. Via this process new ODIS-Non-Fungible tokens are minted representing liabilities for the SPV, and those assets should become available for investment for entire COMDEX (still those need to be routed for final approval of the Board of Directors of SPV before they are offered to the market on COMDEX). Don’t forget that they are taking a legal responsibility to manage and give their face in front of MICA and other authorities in Real World.

We will respond to the rest of the questions, but let’s find a common ground first regarding this profound system architecture related topic.

Best regards

I very much agree on the creditibility being extremely important.
How do you see the node controlling data from the SPV? A blockchain only works if all nodes have the same information. If certain nodes will keep certain subsets of data for itself, then it becomes risky regarding the tamper-proof aspect of that specific data.
The holdings can also be held in something like a DAO or a multi-sig, or maybe even in a group module on newer version of the SDK. No node is required for that.

For me it comes down to two basic questions;

  • is a node really required?
  • if yes, is it required that the SPV owns / controls an own node or is being able to query the data enough?

Hi Community :slight_smile:

As strong proponents of decentralization in the future of financial systems, we emphasize that SPV nodes are pivotal in ensuring transparency, trust, and the integrity of such Real World Business on Comdex ecosystem, while preserving the core principles of decentralization.

As our previous conversations imply, we are both believers of credibility.

Let me try to answer your questions one by one:

“How do you see the node controlling data from the SPV?”

By its very existence and transparency, SPV node (with it’s associated marketing “Liquid Real Estate”), among other validators would play a crucial role in controlling SPV data (when I used word “controlling” I was just referring to set of standard characteristics and capabilities of NODE and information that NODE is able to report out of the box via ALL standard tools existing already in the market. Trust related to those tools is also key here). SPV acting as verifier and record keepers on the Comdex blockchain is clearly indicating that we are committed to the technology stack. This way SPV maintain transparency by ensuring that data, especially related to SPV holdings and compliance, is accurately recorded and accessible to all network participants all the time. Please notice that even current node parameters are already supporting some of the business requirements related to the early stage of RE SPV “Crypto Activity”. For RE owners, coming on chain and tokenizing their assets, comes with associated risks of managing new currency (CMDX in this case). Please remember that they also do their due diligence before they commit their assets. They will indeed ask, what is our level of involvement in the payment network and the community as whole. When confronting such question, SPV will be in a far better positioned if it is able to show that they are among validators. Popularity of such node would tell us a lot about eventual acceptance of the “Liquid Real Estate” token, that captures growing value of all RE assets tokenized in the system. We believe that it would make sense to be on the list below if we want to do it with COMDEX. We are happy to collaborate with someone experienced in this area.

Continuing responding to your points:

Indeed we are conscious that all nodes have the same information for good. Nevertheless, not all nodes looks the same from the way they present them self to the market. We are not intending anything related to keeping certain subsets of data. Having said that, the NODE Webpage could have additional information about the business and their holdings and records. It will make a lot of sense to leverage this communication channel.

Regarding where to keep holdings, indeed, we know that holdings could be held in something like a DAO or a multi-sig (let’s park "group module on newer version of the SDK for seek of simplicity). Yes, we could use other blockchains like DAODAO:

We sincerely appreciate having this very interesting conversation about system architecture options. We understand that one think is the Ideal END-State Architecture for such project, another one is the road map and the best way to get there step by step. Cosmos is offering very interesting possibilities with Cosmwasm and IBC. COMDEX has a lot of elements that would allow to operate very quickly with RE Assets white listed on chain. We could explore building something multi-chain with those chains that provide useful functionality for Real Estate SPVs. We also understand that COMDEX is moving into Cosmwasm as per this post:

There is another very interesting topic related to the format of RE-Non-Fungible tokens (from both SPV capital stacks / debt and equity types). Kindly let us know what is your best understanding (COMDEX view) on developments (if any) of the Security Token Standards on COSMOS, similar to the ERC1400 structure adopted by many: Security Token Standard ( Can we mint something like that directly on COMDEX ?

For those that are not familiar with Polymath who is providing STO on blockchain service:
Please notice that they are focused on services needed for anyone that want to mint security tokens including RE. So in this sense, it is an example of what is available out there for “RE SPV like entity” to tokenize their assets.

I believe that DAODISEO wants to focus more on 3 big areas of opportunities for innovation:

  • RE Assets Due Diligence executed on chain via governance
  • Lean RE SPV operations with on-chain management of assets (Both physical & crypto)
  • Providing retail access to liquid RE Assets contracts

There seams to be many functionalities already built on COMDEX that could be leveraged.

Let’s continue this discussion.
This is helping us a lot to set our next goals and refine the road map.

Out of curiousity; how far in the roadmap are you?
Are you willing to wait on the permissionless CosmWasm or want to go for the permissioned version?
Did you already start some testing with it on the testnet?

Regarding the node; I understand your point regarding the trust is gives, since you would have a share in the security of the network. Are you looking there to run it yourself? Or go for a white-label node?

Regarding the ERC1400 structure; no clue to be honest. I hope the team steps in here to share some insights (@Ismail )