Applicant Information
Name: FundBridge Capital Pte. Ltd. (“FundBridge Capital”)
Address (Headquarters): 39 Duxton Hill Level 4, Singapore, 089617
Country: Singapore
Website: www.fundbridge.sg
Primary Contact
Name: Sue Lynn Lim
Title: Executive Director, CEO & COO, FundBridge Capital Pte. Ltd
Country: Singapore
Email : suelynn.lim@fundbridge.sg, Tel : +65 6535 7888
Key Information
Expected Yield: 3.8%-4% p.a.
Expected Maturity: N/A; open-ended fund
Underlying asset: Singapore Government Bonds (AAA-rated)
Minimum/Maximum transaction size: Minimum investment: $100; Maximum investment: None
Current AUM for product: $0, newly created fund
Current AUM for issuer: S$250,000,000*
*Please note that this amount denotes the AUM managed by FundBridge Capital. As described in greater detail in other sections of this application below, the fund covered by this application, SGD Delta Fund, is the first sub-fund of the Delta Master Trust, a master fund structure designed for launching funds tokenized using the Libeara platform. The SGD Delta Fund has not yet been launched and as such its AUM is $0.
Volume of transactions LTM: N/A, new fund
Source of first-loss capital: N/A
Basics and Background
1. How will this investment improve Arbitrum’s RWA ecosystem?
FundBridge Capital’s SGD Delta Fund (“SGDLTA” or the “Sub-Fund”), a sub-fund of the Delta Master Trust, is a fund whereby its units will be tokenized and issued via the Libeara platform. SGDLTA is the first investment grade-rated token in the Ethereum ecosystem, rated Aa-bf by Moody’s. As such, the tokens represent the introduction of a new primitive in the Arbitrum ecosystem: investment grade-rated assets.
While there are a number of other tokenized fund units in the market, we believe ours is among the most secure due to the legal approach to structuring and the jurisdiction of issuance (Singapore). The fund units are tokenized and issued via the Libeara tokenization platform. Libeara is a new venture incubated and funded by Standard Chartered Bank, its parent. The SGDLTA fund is the first tokenized fund to be launched in collaboration with Libeara, whose roadmap also includes the tokenization of other fund units managed by leading fund managers and bonds issued by governments and corporates.
We believe the Arbitrum community would benefit greatly from the introduction of an investment-grade primitive as well as the institutional presence of Libeara and its partners in the ecosystem. Furthermore, as an SGD-denominated investment linked to a portfolio of securities issued by the Government of Singapore, rated AAA by all three major credit rating agencies, SGDLTA offers currency and geopolitical risk diversification for the Arbitrum Treasury as it pursues its investment strategy.
2. Identify key management personnel and individual experience. Also include third parties utilized for managing assets and their qualifications.
Fund Manager
The Manager of the Fund, FundBridge Capital Pte. Ltd., is a company incorporated under the laws of Singapore and having its registered office at 39 Duxton Hill #04-01, Singapore 089617.
The Manager was incorporated in Singapore on 3 August 2017 and has been managing discretionary funds since 2018. The Manager is currently regulated by the MAS as a holder of a Capital Markets Services License to conduct the regulated activity of fund management in Singapore.
Key personnel at the Manager include:
- Sue Lynn Lim - Sue Lynn serves as FundBridge Capital’s CEO & COO responsible for the business strategy, providing oversight and management of the business including compliance. She has over 20 years of international banking and fund management experience. Prior to FundBridge Capital, Sue Lynn spent 15 years with Standard Chartered Bank from frontline to business strategy where she was eventually an Executive Director in the global office. She was ultimately responsible for Portfolio Management and Sales Performance Management for teams across Asia, Middle East and Africa.
- Bao Vu - Bao is the Investment Director at FundBridge Capital and is responsible for formulating the portfolio allocation strategy, implementation and oversight of fund structures and investment governance of the funds under management. He has over 20 years of global markets and fund management experience, a broad background across different asset classes and is a Chartered Alternative Investment Analyst (CAIA). Bao did his master’s in financial engineering in the prestigious MIT Sloan School of Management. Subsequently, he spent 2 years as a FX structurer at Deutsche Bank before raising to hold director roles across marquee banks such as UBS, Bank of America, and Citibank over the next 14 years in structuring complex deals across all asset classes. In his most recent roles, he advised institutional clients (including some sovereign wealth funds, international asset managers and family offices) on their investments into various proprietary quantitative strategies.
- Fang Suan Lim - Fang Suan is the Head of Risk at FundBridge Capital and is responsible for the overall risk management at the firm, including developing, maintaining and oversight of risk management systems for the company as well as of the funds under management. He has over 25 years of experience in the asset management industry. Prior to FundBridge Capital, he was involved in operations, risk and compliance for a crowdfunding platform. Fang Suan spent 10 years with Lion Global Investors where he was Director, Asian Equities. He was also Director at AGF Asset Management, Head of Equities at NTUC Income as well as held portfolio manager roles at SG Asset Management, Nomura Asset Management and UOB. He graduated from National University of Singapore with a Bachelor of Engineering, Electrical (First Class Honours).
Trustee
The Trustee of the Fund is Perpetual (Asia) Limited, a public limited company incorporated in Singapore whose registered office is 8 Marina Boulevard, #05-02, Marina Bay Financial Centre, Singapore 018981.
The Trustee is currently regulated by the MAS as a trust company licenced under the Trust Companies Act 2005 of Singapore and an approved trustee under Section 289 of the SFA.
The Trustee was incorporated in Singapore on 30 December 2005 and is ultimately owned by Perpetual Limited, which is one of the largest trustees in Australia and is listed on the Australian Securities Exchange.
Prime Broker and Custodian
The Prime Broker and Custodian of the Sub-Fund is CGS-CIMB Securities (Singapore) Pte. Ltd., a company incorporated in Singapore whose registered address is at 10 Marina Boulevard, #10-01, Marina Bay Financial Centre Tower 2, Singapore 018983.
The Custodian is regulated by the Monetary Authority of Singapore and holds a capital markets services license for, among others, dealing in securities and providing custodial services for securities.
Fund Administrator
The Fund has appointed Vistra Alternative Investments (Singapore) Pte. Ltd., whose registered address is 9 Raffles Place, #26-01, Republic Plaza, Singapore 048619, as the administrator of the fund.
Vistra Alternative Investments (Singapore) Pte. Ltd. is part of Vistra Group, a global fund, corporate and private client services company with $395 billion in Assets Under Administration.
Tokenization Technology Provider
The Manager has appointed Libeara (Singapore) Pte. Ltd., whose registered address is 80 Robinson Road, #02-00, Singapore 068898 to provide the technology for issuing and managing the tokenized fund units (the “Delta” technology platform).
Libeara is wholly-owned by Standard Chartered Bank, a leading global banking group.
Fiat On/Off-Ramp Provider
Xfers Pte. Ltd (trading as StraitsX) is the holder of a Major Payment Institution license for e-money issuance under the Payment Services Act 2019. StraitsX has processed over S$5 billion of digital assets related transactions.
Registered office: 79 Ayer Rajah Crescent #04-08, Singapore 139955.
3. Describe any previous work by the entity or its officers/key contributors similar to that requested. References are encouraged.
FundBridge has been managing funds since 2018. The type of assets managed include listed Equities, Fixed Income Instruments, Private Equity, Venture Capital, Infrastructure and Private Debt.
We have been actively managing fixed income portfolios which comprise of mostly corporate bonds and some sovereign bonds in separately managed accounts since 2018.
We are happy to provide references.
4. Has your entity or its officers/key contributors been subject to an enforcement action, criminal action, or defaulted on legal or financial obligations? Please describe the circumstances if so.
No.
5. Describe any conflicts of interest for your entity and key personnel.
None.
6. Insurance coverages, guarantees, and backstops Name of insurer or guarantor Per incident coverage Aggregate coverage
Fundbridge Capital has Professional Indemnity & Director and Officer insurance coverage in place.
7. Historical tracking error in your proposed product, or similar to that being proposed
As a new fund, there is no historical performance to report.
The SGDLTA fund’s strategy is to maximize the total return of the portfolio by analyzing each part of the yield curve for the best risk/reward characteristics, while being mindful of near-term liquidity.
8. Brief reason for above tracking error
N/A.
9. Please describe any experience your firm has in working with decentralized organizational structures
N/A.
10. What is your entity’s current assets under management, assets held in trust, total value locked, or equivalent metric for your legal structuring?
FundBridge Capital’s current assets under management (AUM) is S$250 million (including capital commitments). As a new fund, SGDLTA’s AUM is currently $0.
11. How many of these assets held are present on Arbitrum One, if any?
None at present. However, please note that the fund’s tokenization platform, Libeara, has deployed its platform on Arbitrum One testnet to facilitate the launch of SGDLTA on Arbitrum One in 2024. We are seeking Arbitrum Treasury support to seed the launch, thereby supporting initial liquidity.
Plan Design
1. Describe your proposed product, including a description of the underlying assets and, if more than one asset, the proposed allocation among assets and general investment guidelines. Where appropriate, include targeted maturity mix and credit quality. Attach supplementary documents as appropriate.
SGDLTA is the first sub-fund of the Delta Master Trust, a master fund structure designed for launching funds tokenized using the Libeara tokenization platform. A separate portfolio will be maintained for each sub-fund (including any future sub-fund established under the Fund), and each sub-fund will have its own investment objectives and risks.
The tokenized fund units will be issued from time to time through a series of smart contracts on the permissionless Ethereum blockchain (and such other blockchain(s) as SGDLTA may utilize from time to time) to investors utilizing digital asset wallets accessible in both web-based and application format, such platform services to be provided by Libeara.
SGDLTA will invest in a portfolio of securities issued by the Government of Singapore of varying tenor. The fund will seek to maximize the total return of the portfolio by analyzing each part of the yield curve for the best risk/reward characteristics, while being mindful of near-term liquidity.
SGDLTA may also hold money-market instruments, cash equivalents, money market funds and cash as considered appropriate by the Fund Manager.
Full details of the SGDLTA fund are available in the supplementary documents provided with this application.
2. Do investors have any shareholder, investor, creditor or similar rights?
Yes. Investors are direct unitholders of the SGDLTA fund and are entitled to the rights set out in the trust deed constituting the Delta Master Trust. For further details, please refer to the supplementary documents provided with this application.
3. Describe the legal and contractual structuring for your product including regulatory bodies overseeing your business and the product and identifying all legal jurisdictions interacting with your product. Attach supplementary documents as appropriate.
SGDLTA is the first sub-fund of the Delta Master Trust, an open-ended, umbrella unit trust designed for launching funds where the fund units are tokenized and issued using the Libeara tokenization platform. A separate portfolio will be maintained for each sub-fund established under the Delta Master Trust, and each sub-fund will have its own investment objectives and risks.
SGDLTA has been designed and structured in compliance with the existing financial regulations in Singapore, a leading legal and regulatory jurisdiction. The umbrella unit trust structure was specifically selected as the fund vehicle of choice for SGDLTA due to its many years of use by the industry for open-ended funds (including in the retail investor space) at scale off-chain.
Each of the Manager, the Trustee and the Custodian are regulated by the Monetary Authority of Singapore (the “MAS”) as follows:
- the Manager is regulated by the MAS as a holder of a Capital Markets Services Licence to conduct the regulated activity of fund management in Singapore.
- the Trustee is regulated by the MAS as a trust company licensed under the Trust Companies Act 2005 of Singapore and an approved trustee under Section 289 of the SFA.
- the Custodian is regulated by the Monetary Authority of Singapore as a holder of a Capital Markets Services licence for, among others, dealing in securities and providing custodial services for securities.
Please also note that the Fiat On/Off-Ramp Provider, Xfers Pte. Ltd. (trading as StraitsX), is the holder of a Major Payment Institution licence for e-money issuance under the Payment Services Act 2019.
The primary jurisdiction our product interacts with is Singapore. Please also note that the Sub-Fund, the Manager and/or the Trustee may need to comply, observe or fulfil the requirements or expectations of the laws, regulations, orders, guidelines, codes, market standard, good practices and requests of or agreements with public, judicial, taxation, governmental and other regulatory authorities or self-regulatory bodies in various jurisdictions relating to any matter in connection with its business, including without limitation, tax compliance, anti-money laundering, sanctions, terrorism financing or the prevention and detection of crime.
For further details, please refer to the supplementary documents provided with this application.
4. Would Arbitrum’s assets be bankruptcy remote from your own entity and its officers/key contributors? If so, please explain the legal and contractual basis. On a confidential, non-reliance basis, provide any third party legal opinions to support the conclusions.
Yes. Pursuant to the trust deed constituting the Delta Master Trust, each sub-fund of the Delta Master Trust constitutes a trust separate and distinct from other sub-funds of Delta Master Trust and the assets of each sub-fund are held on trust by the Trustee for the unitholders of the relevant sub-fund. Consequently, the assets of SGDLTA will be held on trust by the Trustee and will not be affected by the liquidation of the Trustee, the Manager, Libeara or the liabilities of other sub-funds of Delta Master Trust. In the event of the liquidation of the Trustee, the assets of SGDLTA will not form part of the Trustee’s own property and will not be included in the pool of assets to be distributed to the Trustee’s creditors.
As indicated in our response to the immediately preceding question, SGDLTA has been designed and structured in compliance with the existing financial regulations in Singapore, a leading legal and regulatory jurisdiction. The umbrella unit trust structure was specifically selected as the fund vehicle of choice for SGDLTA due to its many years of use by the industry for open-ended funds (including in the retail investor space) at scale off-chain.
Full details of SGDLTA are available in the supplementary documents provided with this application.
5. How are Arbitrum’s assets protected vis-a-vis the bankruptcy of the brokerage or applicable financial institution (e.g., bank deposit insurance, securities insurance, etc.)?
Under the terms of the prime services agreement with the Custodian, the assets of SGDLTA are to be segregated from the Custodian’s own assets and reflected as being owned by the Trustee (in its capacity as trustee of SGDLTA). As such, the liquidation of the Custodian should not affect the assets of SGDLTA, which should be assessed by the liquidators to be held on trust for the Trustee (in its capacity as trustee of SGDLTA) and not be included in the pool of assets to be distributed to the Custodian’s creditors. The Custodian, as a regulated entity, is also required by applicable laws to adhere to regulations applicable to the handling of customer moneys and assets.
6. Does the Issuer issue more than one asset? If so, what is the priority relationship between different asset classes?
Each sub-fund of the Delta Master Trust is constituted by a separate and distinct trust.
7. Provide a detailed cash flow diagram that shows the flow of funds from ARB/Fiat conversion, investment in underlying asset, payment of expenses, sale of underlying asset, and repayment (Fiat/ARB conversion), including the counterparties and legal jurisdictions involved.
Onboarding
1. Arbitrum submits KYC and fund onboarding documents.
2. Following Manager review and approval, Arbitrum’s wallet address is whitelisted in the Delta smart contracts.
Subscription
1. Arbitrum sends XSGD to StraitsX via the Delta smart contracts, which is converted into SGD and deposited into the fund’s bank account. Alternatively, Arbitrum can wire SGD fiat directly to the fund’s bank account.
2. The Manager reviews investment requests and reconciles cash received in the fund’s bank account. Following review, fund tokens are minted into Arbitrum’s wallet.
3. On a daily basis, the Manager instructs trades to manage the fund’s portfolio and cash balances.
Redemption
1. Arbitrum deposits SGDLTA tokens into the Delta smart contracts, which triggers a redemption request to the Manager.
2. On a daily basis, the Manager instructs trades to manage the fund’s portfolio and cash balances, creating liquidity to process redemptions when necessary.
3. The Manager reviews redemption requests and wires SGD fiat to StraitsX, who deposits the corresponding XSGD into the Delta smart contract from where it is paid out to Arbitrum’s wallet. Alternatively, the Manager can wire SGD fiat directly to Arbitrum’s bank account.
All entities depicted in the flow diagrams above are located in Singapore.
8. Describe anticipated tax consequences (if any) in transacting on the underlying and/or receipt of yield.
Please refer to section 17.9 of the Information Memorandum, submitted privately as part of the supplementary documentation, for a complete discussion of tax considerations.
9. Describe the process and expected timeline for liquidation of assets, if given instructions to do so by Arbitrum governance.
SGDLTA is an open-ended fund with tokenized units capable of being transferrable P2P between eligible parties on the Libeara Platform, and Arbitrum is free to transfer or redeem its holdings at any time. The manager offers daily redemptions on trading days, with settlement processed within 3-5 business days.
10. What amount of first-loss equity will Sponsor provide to ensure over-collateralization, how is the first-loss equity denominated, and what is the source of capital?
N/A. All fund assets are invested in securities issued by the Government of Singapore. The fund may also hold money-market instruments, cash equivalents, money market funds and cash as considered appropriate by the Manager. The fund is not a lending product.
11. Describe the liquidity and stability of the proposed underlying assets, including anticipated settlement times from the sale of the underlying to the repayment of ARB.
The Government of Singapore is a AAA-rated issuer by all three major credit rating agencies. Bonds and Bills issued by the Government of Singapore traded in average volumes of S$ 3.7 billion per day in 2023. The instruments settle on a T+1 basis.
Redemptions of SGDLTA can be made directly to the Manager on any trading day, with processing completed within 3-5 business days.
Full Singapore Government Security price, yield and volume history available here.
12. If relying on the blockchain for any of the transactional flows, please describe any blockchain derived risks and mitigations.
Like any technology network, blockchains are theoretically vulnerable to outages or attack. Furthermore, risk vectors exist with respect to blockchain-based services including wallets and smart contracts.
In issuing the SGDLTA units on blockchain, the issuer and its service providers have taken specific precautions to protect investors.
The Fund Administrator, Vistra, maintains an off-chain copy of the fund unitholder register, allowing for the reconstitution of investor token holdings in the event of wallet compromise or loss, smart contract corruption or network outage.
Furthermore, as experienced managers and administrators of off-chain funds in addition to the on-chain SGDLTA, FundBridge and Vistra have processes in place to support materialization of fund units and continuity of fund management and investor support in the event of a complete blockchain network outage.
For full details of risks associated with investment in the SGDLTA fund, please see Section 10 of the Information Memorandum, submitted privately in conjunction with this application.
13. Does the product rely on any derivative product (swaps, OTC agreements)?
No.
14. List all the third party counterparties linked to your assets including and not restricted to prime broker if any, custodian, reporting agent, banks for derivatives or loans and provide primary contact details for the third party counterparties
Trustee: Perpetual (Asia) Limited
Contact Details: Phone: +65 6908 8203; Email: contact@perpetual.com.sg
Prime Broker and Securities Custodian: CGS-CIMB Securities (Singapore) Pte. Ltd.
Contact Details: Phone : +65 6210 8626; Email : william.toh@cgs-cimb.com
Fund Administrator: Vistra Alternative Investments (Singapore) Pte. Ltd.
Contact Details: Phone: +65 6438 1330 ; Email: singapore@vistra.com
Fund Bank: United Overseas Bank, Singapore
Contact Details: Phone: +65 6539 3892 ; Email: liow.fangme1@UOBgroup.com
15. Can you explain how is risk management (inv and operational) being done? Can you provide a copy of your risk management policy?
FundBridge maintains a Risk Management Policy Manual and Risk Management Registers on a firm wide basis as well as risk registers for each fund that it manages. This risk management framework covers the risks criteria/tools, frequency of monitoring as well as mitigating controls for inherent risks such as financial, investments, operations as well as legal/regulatory risks. The risk management process and internal controls are audited on a periodic basis with the audit frequency depending on the level of risk. FundBridge’s Board of Directors hold quarterly meetings and risk management, controls and compliance issues are reported to the Board.
Performance Reporting
1. What are your proposed performance benchmarks? If this is substantially different from the underlying assets, please explain why.
Our benchmark is the 3-month SGD Interbank Offer Rate, which is a typical benchmark for Singapore Dollar Short-Duration Government Bond Funds.
2. Describe the content, format, preparation process, and cadence of performance reports. This should include proof of reserves, if appropriate. Please include a sample report.
Investors will be receiving monthly NAV statements as well as daily NAV prices prepared by the Fund Administrator, Vistra.
3. Who provides the performance reports in respect of the underlying assets?
FundBridge will be providing factsheets on a monthly basis.
4. Describe any formal audit process and timing of such audits.
Financial audits are performed on an annual basis.
Pricing
1. Provide a copy of your standard contract, or one similar to what is being proposed here.
Please see Subscription Agreement provided as supplementary documentation submitted privately with this application.
2. Fee summary
A summary of the applicable fees is set out below.
Fees and charges payable by Holders
- Initial Sales Charge (payable to the Fund Manager): Currently none
- Redemption Charge: Currently none
Fee and charges payable by the Sub-Fund*
- Management Fee (per annum): Currently 0.3% of the Value of the Deposited Property of the Sub-Fund; maximum 0.5% of the Value of the Deposited Property of the Sub-Fund
- Trustee’s Fee (per annum): Maximum 0.02% of the Value of the Deposited Property of the Sub-Fund. Subject to a minimum fee as may be agreed between the Manager and the Trustee
- Fee payable to Libeara in connection with the provision of Delta Platforms (per annum): Currently 0% of the Value of the Deposited Property of the Sub-Fund; maximum 0.2% of the Value of the Deposited Property of the Sub-Fund
*Please refer to the Trust Deed for full details of the fees and charges that may be deducted out of the Deposited Property of the Sub-Fund.
In addition, the Sub-Fund shall bear all costs and expenses in relation to the establishment and continued operation of the Sub-Fund out of its assets, including but not limited to:
- all expenses properly incurred for the establishment of the Sub-Fund;
- all expenses properly incurred in connection with the offering of the Sub-Fund; and
- all operating expenses of the Sub-Fund, including any transactional expenses incurred in connection with investments and dispositions, and fees of professional (including legal and audit) advisers.
Please refer to the Trust Deed for further details on the expenses to be borne by the Sub-Fund.
3. Describe frequency of fee payment and its position vis-a-vis payment priority compared with other expenses (i.e., cash waterfall)
Fees and expenses are accrued and deducted on a daily basis.
Smart Contract/Architecture
1. How many audits have you had and name of auditors? Please provide a copy of reports.
The Libeara platform has had one audit, performed by NCC Group in November 2023. Report provided privately in the supplemental documents submitted with this application. All findings in the report have been addressed.
2. Is the project permissioned? If so how are you managing user identities? Any blacklisting/whitelisting features?
Yes. Investors must complete KYC/AML and onboarding with the Fund Manager. Once onboarded, investors’ Ethereum wallet addresses are whitelisted in the Delta contracts, giving onboarded users full access to investment, transfer and redemption functionalities.
3. Is the product present on several chains? Are there any cross-chain interactions?
SGDLTA is currently only available on Ethereum Mainnet. The Delta platform is also currently deployed on Arbitrum testnet, and we are actively working toward the launch of SGDLTA on Arbitrum One in the coming months.
Support for cross-chain interactions is not part of the near-term roadmap.
4. Are the RWA tokens being used in any other protocols? Please describe the various components of the ecosystem
SGDLTA is not yet used in any protocols, though we expect it to be later this year. We view SGDLTA and the subsequent tokenized funds we issue as bridges between TradFi capital and DeFi functionality, especially given our relationship with Libeara, the tokenization platform provider, a wholly-owned subsidiary of Standard Chartered Bank.
5. How are trusted roles/admins managed in the system? Which aspects of the solution require trust from users?
SGDLTA is designed and structured in compliance with existing financial regulations in Singapore, a leading legal and regulatory jurisdiction. The umbrella unit trust structure was specifically selected as the fund vehicle of choice for SGDLTA due to its many years of use by the industry for open-ended funds (including in the retail investor space) at scale off-chain.
The Manager, Trustee, Securities Custodian and fund’s Bank are regulated firms in Singapore with fiduciary duties to SGDLTA investors. Furthermore, processes have been put in place to reconstitute token ownership and materialize tokenized fund units in the event of technical or operational necessity.
Investors trust the Fund Manager and its delegated representative, the Fund Administrator, to mint tokens and process redemptions. Investors trust the fund’s Bank and Securities Custodian to secure the fund’s cash and securities.
All Manager and Fund Administrator platform access is secured by 2FA. All platform access and actions are logged and subject to audit. All on-chain activities, including minting, burning and whitelisting, require Manager approval using Fireblocks MPC.
Internal and external audits and reviews are performed regularly to ensure compliance with operational processes and regulatory requirements.
6. Is there any custom logic required for your RWA token? If so please give any details.
The SGDLTA token contract is built on top of the ERC-20 standard OpenZeppelin contract. The contract employs an on-chain whitelisting mechanism to restrict minting and transfers to wallet addresses owned by duly KYCed and onboarded investors in the fund. The contract also maintains a “clawback” function to recover tokens from lost or compromised wallets, requiring Fund Manager approval using Fireblocks MPC.
Supplementary
1. Please attach any further information or documents you feel would help the screening committee or ARB tokenholders make an informed decision.
The following documents are submitted privately in attachment:
- Information Memorandum
- Trust Deed
- Subscription Agreement
- NCC Audit Report
- Sample of Investor Monthly NAV Report
- Sample of SGDLTA Factsheet
- Moody’s Rating Report