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.
Overview
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).
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)
- 1–2 Onboarding / subscribe–redeem; rupee rails via Habib Bank
- 3–4 FX for overseas; settlement to/from HBL AMC
- 5 Market maker (<2% spread)
- 6 Daily recon of units/securities at CDC
- 7–9 REIT origination, 90-day valuation, units at CDC
- 10–11 Mint/burn/freeze instructions; 2-of-3 MPC signing
- 12–13 HBL reports to PVARA; Cosmic gives PVARA read node
- 14–16 SECP / FBR / evaluation consultations
- 17–19 FMU STRs; Banking Mohtasib; audits to PVARA
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.
| ID | Decision still open | Why 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)
- E-05 Sign MoU with Cosmic Wire
- E-06 Name owners + alternates for every role (Head of Sandbox Ops, tech lead, CISO, CCO, AML, token-agent signatories…)
- E-07 Adopt SGC terms (revise charter — PVARA will not sit)
- E-08 SECP concurrence on tokenised distribution
- E-09 FBR written tax interpretation of tokenised units
- E-10 Shariah adviser determination per pool
- E-02 Close Form I blanks (budget, funding, AUM, Schedule I category, AML officer…)
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)
| Question | Needed for | Status |
|---|---|---|
| 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
- Hosting — provider, region, country for validators and data (C-13; Obs. 9). Still bracketed.
- HBL validators — can HBL run part of the set so Cosmic holds <2/3 voting power? Effort + timeline (Jonathan).
- Pilot audit — firm, scope, completion date (C-01; Obs. 12). Prior “audited” claim on online form is wrong.
- Penetration test — firm + date for pilot RPC/APIs/admin tooling (C-45; Obs. 13). No existing pen-test covers this pilot.
- Stablecoin — confirm none in pilot so HBL can withdraw Fiat-Referenced Token Issuance Services (Obs. 4).
- Architecture pack — business model, component architecture, E2E flows per asset class, fiat flows, settlement/recon, failure paths — due 13 Nov to HBL (Obs. 23).
- Authority read node + log export — C-02 / C-03; who outside Cosmic runs log storage (P-08).
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):
- C-14 Production sandbox network (separate from testnet)
- C-15 Key ceremony (validator, owner, upgrade, agent)
- J-02 Encode on-chain caps in ERC-3643 compliance module
- C-19 Price / NAV input
- C-01 Tier-one smart-contract audit → remediate → no open critical/high
- C-16 Deploy audited bytecode only
- C-17 Identity registry ↔ HBL onboarding
- C-18 CDC + custody position feeds
- C-04 Habib Bank / RDA fiat integration test
- C-02 / C-03 PVARA read node + non-CW log store
- C-40 / C-44 / C-45 Monitoring, capacity (50 TPS / 500 sessions), pen-test
- C-05 Failover drill (RTO ≤2h, RPO ≤15m)
- 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.
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)
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
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
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)
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)
| When | What |
|---|---|
| 8 Oct 2026 | HBL filed — checklist + offering summary only |
| 28 Oct | PVARA 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 evaluation | CW 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.