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December 5, 2023
Inderjit Tuli
Chief Executive Officer
Compound Real Estate Bonds, Inc.
1185 Avenue of the Americas, 3rd Floor
New York, NY 10036
Re:Compound Real Estate Bonds, Inc.
Post-Qualification Amendment No. 2 to
Offering Statement on Form 1-A
Filed November 20, 2023
File No. 024-11848
Dear Inderjit Tuli:
            We have reviewed your amendment and have the following comments.
            Please respond to this letter by amending your offering statement and providing the
requested information. If you do not believe a comment applies to your facts and circumstances
or do not believe an amendment is appropriate, please tell us why in your response. After
reviewing any amendment to your offering statement and the information you provide in
response to this letter, we may have additional comments.
Post-Qualification Amendment No. 2 to Offering Statement on Form 1-A
General
1.We note your response to our prior comment 1 and that you made sales pursuant to the
offering statement after September 19, 2023, twelve months after qualification of the
initial offering statement, the time period when your financial statements were stale. In
this regard, we note that you filed a post-qualification amendment on August 22, 2023,
which has not yet been qualified. Please consider revising your post-qualification
amendment to include risk factor and contingent liability disclosures, as needed,
associated with rescission rights of investors related to the gap period from the staleness
date until the date you suspended sales on November 2, 2023. Refer to Rule 252(f)(2)(i) of
Regulation A.
2.We note your revised disclosure that you plan to raise the interest rate from 7% to 8% on
the bonds you have already issued. Please point us to a provision in your compound bond
agreement that permits you to change interest rates on the issued bonds.

 FirstName LastNameInderjit Tuli
 Comapany NameCompound Real Estate Bonds, Inc.
 December 5, 2023 Page 2
 FirstName LastNameInderjit Tuli
Compound Real Estate Bonds, Inc.
December 5, 2023
Page 2
3.We note your disclosure on the cover page and page 52 that you plan to change the
interest rate from 7% to 8% on the bonds you have already issued to investors. Please
provide us an analysis as to whether you think the increase in the interest rate will result in
a new bond being issued and thus constitute a new security offering. As part of your
response, please also tell us how you think the subsequent offerings will fit within the Tier
2 offering limit, not to exceed $75,000,000. In addition, disclose if you will provide
existing bondholders with a notice of the increased interest rate and provide them with an
opportunity to object or consent to the interest rate change.
4.Please confirm that you will maintain within your website and App, a link to the current
version of the offering statement that is readily accessible for investors considering a
purchase of the bonds. In this regard we note that your website contains a link to the post-
qualification amendment filed on September 20, 2023.
5.Please tell us if investors purchasing through your App have access to the current version
of the offering statement and tell us how you plan to provide them with updated offering
statements going forward.
Offering Circular Summary, page 1
6.We note your disclosure in response to our prior comment 2 and reissue in part. Please
also revise your summary section to describe the potential issues regarding management's
lack of experience.
Interest of Management and Others in Certain Transactions, page 50
7.We note your disclosure here that you owe $28,000 to a related party and on page 4 that
"[a]s of November 10, 2023 [you have] paid approximately $90,000 in offering expenses
and owe ... Affiliates an additional $28,000 for offering expenses paid on [your] behalf."
Please revise your disclosure throughout to clarify the identity of the affiliates and the
amount owed to each affiliate.
Consolidated Balance Sheet, page F-5
8.We note that as of December 31, 2022, you had due to related parties totaling $29,981.
We also note disclosure on page 50 that you currently owe $28,000 in reimbursements to
related parties. We note on page F-14 that there is no outstanding balance in your
consolidated balance sheet as of June 30, 2023, and it does not appear from your
consolidated statement of cash flows on page F-17 that this amount was repaid during the
six months ended June 30, 2023. Please tell us and revise your filing to disclose the
outstanding balance due to related parties as of June 30, 2023 and clarify whether
repayment has been made.
            We will consider qualifying your offering statement at your request. If a participant in
your offering is required to clear its compensation arrangements with FINRA, please have
FINRA advise us that it has no objections to the compensation arrangements prior to

 FirstName LastNameInderjit Tuli
 Comapany NameCompound Real Estate Bonds, Inc.
 December 5, 2023 Page 3
 FirstName LastName
Inderjit Tuli
Compound Real Estate Bonds, Inc.
December 5, 2023
Page 3
qualification.
            We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.
            Please contact Shannon Davis at 202-551-6687 or John Spitz at 202-551-3484 if you
have questions regarding comments on the financial statements and related matters. Please
contact Robert Arzonetti at 202-551-8819 or Tonya Aldave at 202-551-3601 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Finance
cc:       Arden Anderson