Regulatory demonstration · for the Central Bank of Ireland Innovation Hub
How Meithera proposes to build investor protection, transparency and supervision into its architecture
Nine sections: the investor lifecycle, the structure, funds and distribution flows, the simulated ledger, the four open classification questions, the control matrix, the financial model and a market comparison. Nothing here claims or implies authorisation.
Section A
Investor lifecycle
Registration → Verification → Risk assessment → Investment review → Simulated investment → Reporting. Click a stage to see the controls that apply and where the demo shows them.
Registration
A person creates an account. In the demo: a first name and a county; nothing personal.
See it in the demoControls at this stage
- Terms and risk warning shown
- No marketing claims of return
Section B
Investment structure
What an investor holds, and what they do not. Legal rights depend on the final instrument and structure, which remain subject to legal and regulatory review.
Investor
Invests from €100
Profit-participating note
Share of net rent; vote on sale; transfer-restricted
Home's company (Irish DAC)
Owns the home; issues the notes
The home
Legal title stays with the company or borrower
What you own
A note issued by the company that owns the home: economic rights to a share of net rent and the sale proceeds, and a vote. A Raya Chain token records the holding.
What you do not own
The house, or any part of its legal title. The token is a record of the note, not ownership of bricks. “Blockchain-based fractional ownership of property companies” — never “own part of the house”.
Section C
Funds flow
Meithera never holds client money. The involvement and responsibilities of authorised providers are subject to regulatory and commercial assessment.
Investor
Pays from their own bank account
Authorised financial services provider
Payment institution or ECSP: KYC/AML, segregated client account, safeguarding
Home's company / borrower
Receives subscription or loan proceeds at completion
Acquisition & refurbishment
Solicitor's client account; contractor stage payments
Section D
Rental distribution flow
Property → rental income → operating costs → company → investor entitlements → monthly distribution. Live numbers for the Dublin 8 illustration.
Rent collected (month)
€1,920.00
Operating costs
−€500.00 (maintenance, management, insurance, other)
Company net income
€1,420.00
Entitlements
By participation; less 0.5% p.a. ÷ 12
Per €1,000 investor
€4.68 / month, before tax
Each payout is a DISTRIBUTION transaction on Raya Chain to the holder’s pseudonym. Administrators run a month from the admin console; investors see it in Income.
Section E
Blockchain recordkeeping
Entitlement records, the tokenisation concept, transaction references, audit events, distribution records and transfer restrictions — all simulated, all live from this browser's demo state.
Section F
Regulatory decision points
Four questions we are not answering ourselves. Each shows why it matters, points either way, and the assumption the demonstration makes meanwhile.
1. Is the proposed structure potentially within ECSPR (Regulation (EU) 2020/1503)?
Stage 1 · LendingDetermines whether an ECSP authorisation (own or via a partner) is the route to market, the €5m per-project-owner cap, the KIIS, the knowledge test, the €1,000 / 5% warning and the 4-day reflection period.
Points towards “yes”
- · Stage 1 is lending-based crowdfunding to a project owner — squarely within ECSPR's scope
- · Stage 2 notes issued by a per-home company may be 'transferable securities' or 'admitted instruments for crowdfunding purposes'
- · Property Bridges (Ireland) and Bricks (France) operate property crowdfunding under ECSPR
Points towards “no / depends”
- · Consumer lending to natural persons is excluded; the borrower must be a project owner (company)
- · Whether an Irish DAC note is a 'transferable security' depends on its terms
- · ECSPR caps and investor protections constrain scale
Not selected. Demo assumption: None — shown as an open question. All ECSPR controls are implemented 'as if' ECSPR applies.
2. Could the investment instrument qualify as a MiFID II financial instrument?
Stage 2 · Rent shareIf the note is a transferable security outside ECSPR's scope, investment-firm authorisation, prospectus thresholds and MiFID conduct rules follow — and MiCA does not apply to any token representing it.
Points towards “yes”
- · A profit-participating note that is negotiable on the capital market is a transferable security
- · Tokenising a financial instrument keeps it a financial instrument
Points towards “no / depends”
- · Transfer restrictions and a verified-wallet allowlist limit negotiability
- · ECSPR provides its own regime for transferable securities offered via a crowdfunding platform
Not selected. Demo assumption: Instrument shown as 'proposed: profit-participating note' with no classification selected.
3. Could the pooled property structure constitute an AIF under AIFMD?
Stage 2 · Rent shareAn AIF needs an authorised AIFM and a depositary and changes the whole structure and cost base.
Points towards “yes”
- · Capital raised from a number of investors to invest for their benefit in accordance with a defined policy
- · Multi-property 'funds' (Stake Funds, Arrived SFR Fund) are treated as funds elsewhere
Points towards “no / depends”
- · One company per home with an operating purpose (own, refurbish, let) resembles an operating company rather than a collective investment undertaking
- · No pooling across homes; investors choose each home
Not selected. Demo assumption: One SPV per property, operating-company framing — an assumption to test with counsel.
4. Could the platform operate through an appropriately authorised partner?
Stage 1 · LendingA possible route to market without own authorisation at launch; defines who holds client money, performs KYC/AML and is accountable to the supervisor.
Points towards “yes”
- · Licensed ECSPs exist in Ireland; a payment institution can hold client money
- · Partner carries authorisation while Meithera builds the technology and operations
Points towards “no / depends”
- · Partner dependency and margin
- · Division of responsibilities must be clear to investors and the supervisor
- · Raya Chain as an official register (Stage 4) would need its own licence or partner under the DLT Pilot Regime
Not selected. Demo assumption: Funds-flow diagram shows an 'authorised financial services provider' placeholder.
Section G
Compliance control matrix
Proposed controls distinguished from those implemented in the demonstration. Responsible party and the open question for each.
| Control | Purpose | Proposed implementation | Responsible | Status | Open question |
|---|---|---|---|---|---|
| Customer identification (KYC)Stage 1 · Lending | Know who holds each instrument; prevent impersonation | Simulated ID check in onboarding; verified-wallet allowlist on Raya Chain | Authorised partner / ECSP | Partner-dependent | Which entity is the designated person under the CJA 2010? |
| AML / sanctions monitoringStage 1 · Lending | Detect and report suspicious activity | Simulated screening; AML Monitor agent flags; FREEZE tx with reason code | Authorised partner; Meithera (tooling) | Partner-dependent | Thresholds and reporting lines for a €100-minimum platform |
| Investor classificationStage 1 · Lending | Apply the right protections (sophisticated vs non-sophisticated) | Self-declaration in onboarding; classification shown to supervisor | ECSP | Implemented (demo) | Evidence standard for self-certification (ECSPR Annex II) |
| Entry knowledge test & loss simulationStage 1 · Lending | ECSPR Art. 21 — understanding and ability to bear loss | 5-question test (pass 4/5), loss-bearing simulation, results in audit log | ECSP | Implemented (demo) | Retake policy and frequency of re-assessment |
| Investor risk disclosuresStage 1 · Lending | Fair, clear, not misleading; specific warning above €1,000 / 5% | Exact risk warning everywhere; threshold warning with express consent; KIIS card | ECSP; Meithera (content) | Implemented (demo) | Approval process for marketing communications (ECSPR Art. 27) |
| Reflection periodStage 1 · Lending | ECSPR Art. 22 — 4-day pre-contractual withdrawal | Withdrawal button on confirmation; CORRECTION tx returns units | ECSP | Implemented (demo) | Treatment of funds during the period |
| Client money handlingStage 1 · Lending | Investor funds never at platform risk | Funds-flow diagram: payment institution with segregated accounts; Meithera never holds money | Payment institution | Proposed | Which payment institution; safeguarding arrangements |
| Investment recordkeepingStage 2 · Rent share | Accurate register of holders and entitlements | Off-chain register authoritative; Raya Chain mirror with hash-chained blocks and anchors | Meithera; SPV company secretary | Implemented (demo) | Legal status of the on-chain record (Stage 4) |
| Asset custodyStage 2 · Rent share | Safekeeping of instruments and the property | Property held by the SPV; notes registered; custodian needed for Stage 4 | SPV; custodian (Stage 4) | Proposed | Custody model for tokenised notes |
| Transfer restrictionsStage 2 · Rent share | No transfers to unverified or frozen holders | Allowlist rule evaluated on every TRANSFER; rejected tx recorded with reason | Meithera (tooling); ECSP (policy) | Implemented (demo) | Bulletin-board settlement under ECSPR Art. 25 |
| Complaints managementStage 1 · Lending | ECSPR Art. 7 — effective and transparent handling | Simulated complaints register visible to supervisor | ECSP | Implemented (demo) | FSPO access depends on the authorised entity |
| Business continuity & wind-downStage 2 · Rent share | ECSPR Art. 12 — continuity of service to investors | Documented per-SPV exit; ring-fenced companies | ECSP; Meithera | Proposed | Who administers SPVs if the platform ceases |
| Data protection (GDPR)Stage 0 · Demo | Lawful processing; minimisation | No personal data in demo; pseudonymous holder IDs on chain; DPIA for production | Meithera; partner | Implemented (demo) | Right-to-erasure vs immutable ledger (mapping lives off-chain) |
| Human oversight of AIStage 0 · Demo | EU AI Act — no automated decision without a person | Every agent output requires approval; approvals in audit log | Meithera | Implemented (demo) | Risk classification of the AML Monitor |
| Supervisory reportingStage 1 · Lending | Timely, accurate information to the supervisor | Read-only supervisor view; CSV/JSON export; monthly report draft | ECSP | Implemented (demo) | Format and cadence the Central Bank would want |
Section H
Financial model
Base, optimistic and downside cases from the same engine that powers every figure on the site.
Interactive financial model
Edit any input. Every output is recomputed by runModel(); scenarios adjust rent, vacancy and costs.
Inputs as entered.
- Total project cost
- €290,000
- Gross yield
- 8.28%
- Collected rent (after vacancy)
- €23,040
- Operating costs incl. management
- −€6,000
- Net operating income
- €17,040
- Property-level NOI yield
- 5.88%
- Participation
- 0.345%
- Investor share of NOI
- €58.76
- Administration fee
- −€5.00
- Investor income (before taxes)
- €53.76 · 5.38%
| Scenario | NOI yield | Investor income | Investor yield |
|---|---|---|---|
| Base case | 5.88% | €53.76 | 5.38% |
| Optimistic case | 6.49% | €59.88 | 5.99% |
| Downside case | 4.30% | €37.97 | 3.80% |
Illustrative. The downside case can produce a negative investor income: that is the point of showing it.
Section I
How Meithera compares
From docs/competitor-analysis.md. Figures are self-reported by platforms or third-party reviews and may be out of date.
| Platform | Market | Regulatory basis | Investor holds | Min. | Income | Exit | Fees |
|---|---|---|---|---|---|---|---|
| Meithera (proposed) | Ireland / EU | ECSPR (partner first, own licence later) — subject to regulatory assessment | Stage 1: secured loan participation · Stage 2: notes in a per-home company | €100 (illustrative) | Monthly (illustrative) | Investor vote; ECSPR bulletin board; no promised liquidity | 1.5% acquisition + 0.5%/yr administration; loans: borrower pays 1.5% |
| Stake | UAE, KSA | DFSA property crowdfunding operator | Shares in a per-property SPV registered with Dubai Land Department | AED 500 | Rental dividends | Exit windows + investor votes | Not published on review page |
| PRYPCO Mint | UAE | With Dubai Land Department; VARA-licensed | Tokenised title deed registered by DLD | AED 2,000 | Monthly rent | Marketplace; majority vote to sell | 2% entry, 1% exit, 0.5%/yr, 15% of appreciation |
| Arrived | US | SEC Reg A+, series LLC per property | LLC series shares | $100 | Rental dividends | Monthly P2P windows after 6 months; 5–7 yr hold | Up to 3.5% sourcing, ~0.6%/yr, 8% of rent PM |
| Lofty | US | No published exemption — untested | Wyoming LLC tokens on Algorand | ~$50 | Daily USDC | Order book + AMM | 2.5% buy / 3% sell |
| Bricks.co | France / EU | AMF ECSP licence; Lemonway payment agent | Bonds / SPV interests | €10 | Monthly | None advertised | €0 to investors |
| Property Bridges | Ireland / EU | Central Bank of Ireland ECSP authorisation | Loans to Irish homebuilders | — | Interest | — | — |
Lex Markets (US)
Liquidity is a platform service, not a property of the instrument. Never promise a secondary market; document wind-down.
RealT (US)
Tokenisation does not remove landlord obligations. Property management, RTB and tenant welfare are first-class.
Lofty (US)
Regulatory-first, not token-first. Show realised vs projected separately.
Arrived (US)
One-screen fee stack, gross → net walk, plain illiquidity warnings.
UK wind-downs (Property Partner, British Pearl, Bricklane)
Ring-fenced SPVs, independent custody of client money, a documented exit for every SPV.
Differentiators: realised vs projected always separate; full ECSPR protection UX; impact reporting (projected, not achieved); a supervisor view; Raya Chain audit record.