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CORRESP
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April 11, 2025

Madeleine Joy Mateo & Susan Block

Office of Finance

Division of Corporation Finance

    Re:
    Compound Real Estate Bonds, Inc.

Post-Qualification Amendment

to Offering Statement
on Form 1-A

Filed March 21, 2025

File No. 024-11848

Ms. Mateo & Ms. Block:

Please see below for responses
to the Division’s letter dated April 4, 2025 regarding the above captioned matter. All questions have been addressed in the Company’s
Amended 1-A, filed April 11, 2025 (“APOC”), as further herein detailed.

Sixth Amended Preliminary
Offering Circular Dated March 21, 2025

Risk Factors, page
8

 1. We note your response to prior comment 1 and your disclosure on page 46 that 75% of your loan portfolio
was concentrated in a single loan secured by an industrial property in the Canadian Province of Ontario. Please add a risk factor discussing
any material risks related to loan concentration, if applicable, or advise.

The Company has added a risk factor
to the APOC as requested.

The Company may be
subject to fines and penalties for its failure to file, page 16

 2. We note your response to prior comment 2. Please tell us how many of your outstanding Compound Bonds'
interest rates were permanently increased. Also please revise this risk factor to quantify the amount of securities that had an increase
in interest rate without filing a supplement or post-qualification amendment.

At the time it increased the interest rate
being paid to the bondholders, the Company had 208,259 Compound Bonds outstanding which were originally issued for $10 each. The referenced risk factor has been revised to include
this information.

 3. We note your responses to our prior comments 2 and 3. We note your response that the company unilaterally
changed the interest rate on the bonds, but there is no such express provision in the bond agreement to unilaterally change the interest
rate. Please explain to us how the change in interest on the bonds is effectuated. We note your disclosure that the company believes
that forcing a bond holder to affirmatively trade their current bonds for a new bond with a higher rate could create unfairness if a bondholder
did not know action was needed. As part of your response, please tell us how bondholders are notified of the change.
Also, please explain how the change in interest rate would constitute this being a continuous offering.

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To
effectuate the change, the Company undertook the following internal actions:

 1. Company
                                            Approval & Documentation: The Company’s executive management documented the decision
                                            via internal approval protocols and archived this documentation for compliance purposes.

 2. System
                                            & Ledger Updates: Following approval, the Company updated its internal accounting and
                                            bond ledger systems to reflect the new 8.5% APY for all active Compound Bonds. This included
                                            modifying the interest calculation logic, accrual templates, and reporting formats within
                                            its financial systems and statements.

 3. Operational
                                            Coordination: Internal teams—including accounting, compliance, product, and customer
                                            service—were briefed on the change. Procedures were updated to ensure consistent investor
                                            communication and back-end handling aligned with the new rate.

Bondholders
were notified of the interest rate increase using multiple channels, including:

 ● Direct
                                            Email Communication: On April 5, 2024, the Company sent an email to all registered bondholders
                                            with the subject line “Important Update: Interest Rate Increase to 8.5%apy
                                            Bonds Effective April 9”. This email informed investors that the interest rate
                                            increase would apply across all existing accounts for existing bondholders. On April 9, 2024,
                                            the Company sent an email to all registered bondholders titled “Important Reminder:
                                            Interest Rate Increase to 8.5%apy Bonds Effective April 9,” which reiterated that
                                            the rate increase would automatically apply to all existing bonds held by investors and would
                                            be valid indefinitely for all new and existing bonds.

 ● Investor
                                            Portal Dashboard Notification: Upon logging into the investor dashboard, bondholders
                                            saw a system-generated notification displaying the interest rate increase.

 ● Public
                                            Posting: A notice of the interest rate increase was displayed on the Company’s website.

This
increase in interest rate was implemented across the entire outstanding balance of all outstanding bonds simultaneously, and no bondholder
action was required to receive the increased interest rate.

The increase in interest rate on the Compound
Bonds and the Company’s notification to investors concerning that interest rate did not halt or otherwise affect the continuous
nature of the Company’s Regulation A offering. Rule 251(d)(3)(1) allows for continuous offerings so long as (F) “Securities
the offering of which will be commenced within two calendar days after the qualification date, will be made on a continuous basis, may
continue for a period in excess of 30 calendar days from the date of initial qualification, and will be offered in an amount that, at
the time the offering statement is qualified, is reasonably expected to be offered and sold within two years from the initial qualification
date.” The Company’s Offering Statement was most recently qualified on February 5, 2024. Sales of Compound Bonds had commenced
by February 7, continued for more than significantly longer than 30 days, and did not cease at any point because of the interest rate
increase (either before or after April 2024). The interest rate increase did not have any impact on the mechanics by which, or the ability
of investors to buy or redeem their Compound Bonds, or the time take by the Company’s system to process and close on those orders.

We appreciate your time and attention in this matter.

            Sincerely,

            /s/ Dodson Robinette PLLC

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