Cosmic Wire · Internal · For Vinny

HBL AMC × PVARA — detailed status

What HBL still must decide on scope and technology, the Cosmic Wire build sequence that hangs on those answers, and how the system fits together. Drawn from the HBL AMC and Cosmic Wire implementation plans in Drive.

Portal deadline 27 Nov 2026 Scope gate E-01 / S-01–S-11 before CW build Arch pack due 13 Nov to HBL As of 2 Nov 2026 · SBX-2026-00024

Overview

PVARA observations
24
HBL scope decisions
S-01–S-11
Working envelope
PKR 400m
Form I on Portal
Not filed

HBL AMC is the PVARA sandbox applicant. Cosmic Wire operates the permissioned Layer-1 and ERC-3643 token stack. Habib Bank is the fiat rail; CDC is registry of record; Zodia is the named institutional custodian. Cosmic’s token, custody path, coupon/distribution flow and reconciliation differ by asset class — so the HBL implementation plan makes Cosmic’s production build wait on HBL’s scope ratification (E-01 / Section 4).

Attachment notes: the 80+ page PDF pack will be sent separately by Keli. PVARA Application v18 is in the Implementation Plan folder (open v18). Portal currently has checklist + offering summary only (Obs. 20).

Latest plans: HBL AMC Implementation Plan · Cosmic Wire Implementation Plan · Observations Q&A.

System diagram

From the HBL AMC implementation pack — PVARA sandbox pilot: parties and flows (based on application v18). This is the canonical party / money / token / reporting map Cosmic builds against once HBL answers S-01–S-11.

Source file: PVARA_Sandbox_Parties_and_Flows.png (companion to HBL AMC — PVARA Implementation Plan). Click image for full resolution.

How to read it (numbered flows)

Pending HBL scope decisions

From HBL AMC Implementation Plan §4. These are business decisions for HBL’s investment/risk committee. Cosmic builds after ratification (E-01 → M-03). Swapping an asset class later is an SGC change request and can move go-live.

Faisal’s early signal (“money market funds and our HBL asset app”) is too vague to start tokenization. Cosmic still needs named schemes, dealing rules, and which exact consumer app — otherwise Jonathan cannot size the integration.
IDDecision still openWhy it blocks Cosmic
S-01 Scope Which business line owns the pilot, budget and results? Day-to-day CW counterpart and change-approval path
S-02 Scope Funds/ETF pool PKR 200m — which schemes by name? NAV strike, cut-off, redemption period, minimum, Shariah? Each scheme = its own token + dealing rules; v18 requires NAV frequency filed before a scheme opens
S-03 Scope Gov securities PKR 160m — which T-bills/bonds? Acquire how, hold where, coupons how? Issuance, coupon payment and reconciliation design for that pool
S-04 Scope REIT pool PKR 40m — which REIT, properties (3–5), trustee, developers, valuer? Listed? CDC cannot fractionalise units; fractional tokens sit over a whole unit — design is REIT-specific
S-05 Scope Cohort sizes (existing / new / Roshan), ramp in first 3 months, ticket sizes Onboarding capacity, support staffing, go-live load test
S-06 Scope Expected redemption volumes; 5% cash reserve funding; market maker + capacity Exit-without-forced-sale and <2% spread promise in the filing
S-07 Tech Customer channel — existing HBL AMC app, new app, or portal? Who builds/runs UX? Sets integration scope from front end into Cosmic rails (multi-phase)
S-08 Tech Current KYC process/provider; video ID already? How are Roshan customers onboarded today? Identity-registry binding design before C-17
S-09 Tech Which HBL accounts receive subscriptions / pay redemptions? RDA + FX flow? Fiat-rail integration (C-04) and daily reconciliation
S-10 Tech Which limits on-chain vs ops? Where does NAV/PKR price feed come from? On-chain caps need audited upgrades; price feed = C-19 / J-02 / J-04
S-11 Tech Internal + PVARA report formats needed from the platform Build reporting once against P-02 agreement with PVARA

Also “start now” on HBL (does not wait for approval)

Key technology questions still pending

Drawn from both implementation plans + the Cosmic Q&A draft for PVARA Obs. 9 / 12 / 13 / 23. These are the items that either block the production build or block a credible Portal response by 27 Nov.

1. Critical path dependencies (HBL → Cosmic)

QuestionNeeded forStatus
Blocker Named instruments (S-02–S-04) ratified Token models, J-02 caps, Obs. 3 / 23 flows Open — Faisal vague (“MMFs + asset app”)
Blocker Which front-end app (S-07) App ↔ Cosmic API integration phases Open
Blocker KYC stack today (S-08) + video ID Identity registry binding (C-17) Open
Blocker Fiat accounts + RDA path (S-09) Habib Bank integration testing (C-04) HoTs only; not executed
Blocker On-chain vs ops limits + NAV feed (S-10 / J-04) Compliance module + price input (J-02, C-19) Open
Tech Token-agent signing policy (H-33 / P-07) Key ceremony (C-15), recovery 2-of-3 (C-08) Draft positions; HBL names pending
Tech CDC + Habib Bank agreements executed Rehearsal J-01; live testing CP Advanced HoTs only
Tech Zodia confirmed (or replacement) Custody feed C-18; Obs. 10 Unconfirmed

2. Cosmic Wire answers PVARA still needs filled

3. Pre-go-live tech gates (from Cosmic plan §6)

Build order once J-04 / H-33 close (during evaluation — do not wait for Letter of Approval):

  1. C-14 Production sandbox network (separate from testnet)
  2. C-15 Key ceremony (validator, owner, upgrade, agent)
  3. J-02 Encode on-chain caps in ERC-3643 compliance module
  4. C-19 Price / NAV input
  5. C-01 Tier-one smart-contract audit → remediate → no open critical/high
  6. C-16 Deploy audited bytecode only
  7. C-17 Identity registry ↔ HBL onboarding
  8. C-18 CDC + custody position feeds
  9. C-04 Habib Bank / RDA fiat integration test
  10. C-02 / C-03 PVARA read node + non-CW log store
  11. C-40 / C-44 / C-45 Monitoring, capacity (50 TPS / 500 sessions), pen-test
  12. C-05 Failover drill (RTO ≤2h, RPO ≤15m)
  13. J-01 Closed-cohort rehearsal on integrated stack → then customer funds

Proposed Cosmic Wire development plan

Synthesis of the Cosmic Wire Implementation Plan phases with the observation response calendar. Principle from Keli: do not base the build calendar on approval — prepare as if approval can arrive early; the long pole is audit.

PHASE 0 · Now → 13 Nov 2026 · Response & design lock

Unblock Portal answers + freeze architecture assumptions

  • Keli confirms 13 Q&A positions; fill hosting, auditor, pen-test dates
  • Jonathan: validators for HBL, hosting, audit firm, pen-test firm, stablecoin confirm, review draft flows
  • Deliver Obs. 23 architecture + transaction-flow pack to HBL by 13 Nov
  • Push HBL for E-01 scope answers (at least Phase-1 MMF shortlist + confirmed app) so token work can start
  • Commercial: Faisal PM proposal path (parallel, not on tech critical path)
PHASE 1 · 13 Nov → 27 Nov 2026 · Portal package support

HBL Portal response + Cosmic technical annexes

  • Cosmic-owned Obs. 9 / 12 / 13 / 23 answers finalised
  • Tech inputs into Form I, testing-plan KPIs/KRIs, wind-down steps, tech risk register
  • Charter revised (PVARA seat removed); MoU / term sheet narrative corrected
  • HBL resubmits application (~20 Nov proposed) then Portal response by 27 Nov hard
PHASE 2 · Dec 2026 → Letter of Approval · Production build during evaluation

Start C-14→C-01 sequence as soon as J-04 / H-33 close

  • Provision production sandbox network; key ceremony; encode caps; wire NAV feed
  • Commission and run tier-one audit (longest single task — do not wait for LoA)
  • Commission pen-test of RPC/APIs/admin tooling in parallel once stack exists
  • Stand up PVARA read node + external log store
  • Begin Habib Bank / CDC / KYC / app integration stubs against agreed interfaces
If scope (E-01) is not decided before January, the plan’s “build committed from January” assumption slips and go-live moves with it.
PHASE 3 · Post-LoA → ~8 weeks · Integrate, harden, rehearse

Only verification + rehearsal should remain after approval

  • Deploy audited contracts; complete C-17 / C-18 / C-04 end-to-end
  • Hand issuer ops tooling to HBL staff (C-42); train; incident runbook (C-41)
  • Capacity proof (C-44), failover drill (C-05), closed-cohort rehearsal (J-01)
  • File audit + rehearsal evidence as conditions of live testing (H-42 / P-16)
PHASE 4 · Go-live → +12 months · Operate sandbox

Live test ops

  • Run validator set; SGC attendance; 1-hour tech facts for PVARA notices
  • Reporting metrics; 7-year retention; ISO 27001 evidence for CW-operated infra
  • Wind-down rehearsal once; re-audit on any material contract change

Suggested Phase-1 product cut (if HBL prioritises safety over yield)

Per internal guidance: if the objective is “don’t break anything,” start with Shariah-compliant money market funds only, then stage gov securities / REITs. That still requires S-02 names — not just the asset class label — and a confirmed app (S-07) before integration estimates are real.

Timeline (compressed)

WhenWhat
8 Oct 2026HBL filed — checklist + offering summary only
28 OctPVARA 24 observations issued
4 Nov (prop.)Keli confirms CW positions; fill blanks
13 Nov (prop.)CW → HBL architecture/flows + draft answers
20 Nov (prop.)HBL resubmits application
27 Nov (hard)Portal response deadline
During evaluationCW production build + audit (do not wait for LoA)
Early Jan 2027*Earliest LoA if screening closed with filing
Q1–Q2 2027*Rehearsal → go-live planning window

*Indicative from implementation plans.

Drive sources