MakerMan delegate platform

Delegate Communication:

Supported current hat.

** Aave D3M Onboarding and Core Unit Budget Transfers - October 29, 2021**

Delegate Communication

Poll votes:

Parameter Changes Proposal - MakerDAO Open Market Committee - November 1, 2021 - rate changes are reasonable and will boost revenue by roughly 1M/month.

** Lower PSM Vault Fees - November 1, 2021** - against lowering tin/tout to zero as this is going to crush returns on all DAI-stablecoin lps. People believe this is good, when in fact it is likely to lead to negative market and liquidity implications. Interestingly this move counterintuitively might actually decrease the DAI in circulation vs. increase it I believe we need to go to 20tin/tout and slightly increase the spread.

** Community Greenlight Poll - MDI (MD Irradiance LLC) - November 1, 2021** - abstained becuase I agree with @PaperImperium in that some thinking about how MakerDAO handles greenlight polls is appropriate. I honestly would rather CUs be the ones to bring these forward or stop them. I don’t want to consider things unless one or MORE CUs has co-sponsored a proposal for the DAO.

** Community Greenlight Poll - OHM (Olympus DAO) - November 1, 2021** - I had to think a lot about this poll. I am not convinced Olympus products (OHM) are sustainable at this time. Perhaps in a 3-6 months I may change my view. I also just believe that Maker needs to focus on onboarding collateral and vaults that can lead to B’s of DAI minted with the least correlated risk exposures. The fact that OHM is already using DAI heavily is something to monitor carefully.

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Delegate Communication:

Executive blocking vote:

** Parameter Changes, Core Unit Budget Distribution - November 5, 2021 ** - I am voting my 5K MKR on on the ** MOMC Proposal, August Core Unit Budgets, Housekeeping - August 6, 2021 ** proposal to attempt to block the current PSM tin/tout set to 0 by taking my 5K away from supporting current Executive and supporting an old Executive raising the needed MKR to pass current Exec to 51.65K MKR.

Reasons are straightforward and as follows:

  1. Setting PSM tin/tout 0 signals that Maker wants DAI price below 1 and when the PSMs empty it is going to swift. We are already down almost 1B in 30 days on the USDC PSM. If this isn’t a wake up call to MakerDAO I don’t know what is.
  2. If more PSMs are added Maker will become the defacto Monopoly stablecoin trading platform where all Maker PSM stablecoin prices (regardless of risk) will trade at $1. USDP and USDC will be the first to have locked prices. IF for any reason there is a market loss event that is traced to Maker price fixing stablecoins via the PSMs it likely will lead to the end of Maker and DAI.
  3. PSM spread to zero will basically eliminate stablecoin trading fees in vaults like GUNIV3USDCDAI etc. I would rather us open up the tin/tout to 20bps and these trading markets to get more liquidity and be more robust than killing stablecoin trading on curve and uniswap in one fell swoop by taking away trading fees. This may take a while for markets to digest but in time it will.
  4. If this still passes it will mean a greater agreement with MKR holders to support this. Hopefully causing people to consider more carefully what MakerDAO gets from passing this, and what it hazards.
  5. Locking DAI PEG through stablecoins was originally intended to be an ‘emergency’ measure but has become the defacto method of choice to maintain the PEG. Liquidity into and out of the sides of the DAI with some spread away from 1 IS critical. We have used low price of 1 and high price > 1 at some point we will seriously want to consider bracketing a bracket < 1 and 1. I have been just advocating we always have a fee away from 1 proper (both tin/tout > 5bps) vs. what this proposes =1 on both sides of the PEG. tin/tout=0 setting will coil up the maximum possible financial energy should the PEG have any real financial reason to deviate from 1.(I have listed numerous ones). Having a spread acts as a financial cushion, LP in pairings acts as the liquidity source(s) for immediate trading.

I want to be clear I am for everything else in this executive. MOMC fee and parameter changes, core unit budget requests (even though I see many of these funding requests being high - I am pleased to see initiatives by various core units to return excess funds). But I feel strongly enough to push those changes to next executive to stop the PSM tin/tout 0 from passing and being enacted.

I don’t like to use the MKR delegated to me to block a proposal but there are times when you are so sure something is wrong that you want to do everything reasonably possible to stop people from doing something that has a great potential to harm their own business and other people’s livelihoods. To be sure if this passes the effect probably won’t happen immediately but when the PSMs are finally drain it will happen quickly and governance will not be able to act fast enough to stop the outflows and a PEG dropping rapidly below 1.


Delegate Communication 20211113_1221UTC

Poll votes:

Add WBTC-B as a new Vault Type - November 8, 2021 - voted YES because this supports my thesis (posted long ago) regarding having multiple vaults on the same collateral type to allow markets to decide their risk exposure, rate they will pay and to manage DC. These types of vaults allow for a more staggered liquidation should prices drop.

GUNIV3DAIUSDC-A Parameter Adjustments - November 8, 2021 - voted YES even though PSM tin/tout to 0 over time is going to kill fees here. Mostly because I am expecting the DAI PEG to break 1 - and will bring fees back. The use of this vault is going to depend heavily on whether Maker can maintain PEG at 1 or not and fees.

NS-DROP Covenant Modification - November 8, 2021 - voted NO on these changes. Simple upshot here is that while work is being done to correct issues with Centrifuge structure until the structures are more suitable for Maker (for example a senior secured credit agreement seat) there is a general consensus not to modify these to/and/or extend new credit. There are significant issues going on with RWF in general well that are creating additional opacity making these difficult to deal with.

Recognised Delegate Compensation Increase - November 8, 2021 - voted YES Even if I wasn’t a delegate I would have voted my MKR for this. I believe the work being done by delegates justifies the compensation. I do believe given the level of compensation there should be a solid set of measurable requirements. I am also concerned that there is no cap on MKR that can be delegated to a single delegate.

Increase the WSTETH-A Debt Ceiling - November 8, 2021 - voted YES to the increase here. We really want to encourage collateral that earns return.

DIRECT-AAVEV2-DAI Parameter Adjustments - November 8, 2021 - voted YES to the increase here. I have wanted Maker protocol to take advantage of earning return on DAI and this is one of many ways. I do have concerns over implications on liquidity, security and if DAI runs off PEG.

Executive: Parameter Changes, Return Unused Budget to the Surplus Buffer - November 12, 2021 - Supported Increases GUNIV3DAIUSDC-A DC from 50 to 500M, decreases the LR to 102 - basically going to 50x leverage from 20x. SF decreased from 1% to .5%. I am positive on these types of vaults for multiple reasons. One thing to point out is that this v3 liquidity is concentrated into a very narrow band. If for any reason the PEG drops below this band this LP will earn no fees and people will need to reposition. While unlikely to see a 200bps drop DAI below PEG here could cause this vault to become under collateralized. Hence like all the stablecoin vaults that have stablecoin values PEGGED to 1 create some systemic risk should underlying stablecoin collateral drop significantly below $1 for any reason.

WSETH-A DC increase - very much needed and likely will be used.

AAVEV2-DAI Aave D3M - While there are some hazards at least the protocol is now earning fees using DAI in these DeFI projects. About time honestly.

It was nice to see some surplus budget returned tot he surplus buffer but as can be seen later there are some CU accounting issues to be addressed.

Last notes.
USDC PSM down over 250M in past 5 days. Puts us on track to empty by year end.
Also concerned over the turmoil going on within the RWA unit around @SebVentures and Cenrifuge slowing down RWA growth
Beyond this we are about to hit top end of surplus buffer and DAI holding at 8B earning over 1% in aggregate.

Upcoming Polls

Community Greenlight Poll - MDI (MD Irradiance LLC) - November 1, 2021 - probably going to abstain as I agree with Paper the process around these greenlight polls needs to be changed.

Community Greenlight Poll - OHM (Olympus DAO) - November 1, 2021 - still a No on Olympus OHM.

Ratification Poll for Adding the Deco Fixed Rate Core Unit (DECO-001) - November 8, 2021 - Honestly there are so many issues around Deco. If this unit came on as a parallel PECO to work on what governance wanted and set aside this fixed rate stuff I would be more supportive. Setting aside my issues around fixed rates:

  1. Maker can fix rates all by itself. It doesn’t need to do this in the protocol
  2. Maker by creating fixed rate instruments increases the likelihood of regulation being applied to the protocol.
  3. Won’t do dink to get us out of the rate issues in the Impossible Trinity

Put simply this particular deal basically gives Deco a huge benefit from the protocol, while the protocol takes on all the risk. No government, no institution would give away so much to get so little and take on such risk. As structured Deco is a bad deal for Maker. This idea that if we don’t do it, DECO will be upset and take their marbles off the table is concerning to say the least. It is as if some inside deal was done here and governance is just supposed to rubber stamp a yes. I have various folks both inside and outside Maker lobbying me on both sides of this deal with valid reasonings. I am still willing to hear a cogent argument for why this is good for Maker vs. what we lose if we don’t do it. I have never liked a business deal which was a lose-lose proposition if I didn’t do it. Tells me the deal is structured badly because in any good deal saying no just means things stay the same (no-one loses - we just don’t gain).

Ratification Poll for Supplement to Collateral Onboarding Application (MIP6c3-SP1) - November 8, 2021 - Going to support with YES this. Don’t know what I ended up at the first time I looked for this but after finding this and reading it a resounding yes.

Ratification Poll for the Immunefi Security Core Unit (IS-001) - November 8, 2021 - Leaning to YES here mostly based on discussions with other CUs etc. We need to grow a bit more with manpower and this unit will manage some other key MakerDAO issues. Really want to see expenses come in line. Particularly the MKR vesting since we are seeing MKR being vested for unfilled positions in a number of CUs now.

Ratification Poll for Modify Core Unit Budget, RWF-001 (MIP40c3-SP39) - November 8, 2021 - First glance is to support this because we really need RWA to get moving and I see this CU as needing really qualified and experienced people and these don’t come cheap. Honestly moving to side with PaperImperium here regarding wanting these to be resubmitted with MKR vesting for current positions not vacant ones.

Ratification Poll for Modify Core Unit Budget, COM-001 (MIP40c3-SP40) - November 8, 2021 - Probably going to support this.

Ratification Poll for Real-World Finance Core Unit MKR Compensation, RWF-001 (MIP40c3-SP38) - November 8, 2021 - in principle for MKR compensation but I don’t like seeing this vesting for empty positions. I also would like MKR compensation to be tied to net DAI profits and MKR being continually purchased from these profits and held to fund DSSVest.

Ratification Poll for Modify Core Unit Budget, MKT-001 (MIP40c3-SP33) - November 8, 2021 - Generally going to support (same comments as above). Still looking at budgets somewhat.

Ratification Poll for Adding Sidestream Auction Services Core Unit, SAS-001 - November 8, 2021 - Yes here as it is my hope to have a single unit looking over all the details of auctions. My issue here is this unit appears to have a analytics cost component that I would expect should be offloaded to the Analytics CU. We really need to focus all data analytics needed for CUs through this CU vs. everyone doing their own stuff. This is also true of UIs.


Delegate Communication 20211116_1231UTC

Poll votes:

Local Liquidation Limit Adjustments for ETH-A, ETH-B, ETH-C, WBTC-A and WSTETH-A - November 15, 2021 - voted YES

Rates Proposal - November 15, 2021 - voted YES I have a bit of concern these changes are pretty high (2-4% especially) and will cause some payback but this will give some extra income and give us a good look at change in demand due to rate. Given rate of decrease of the PSM higher rates are in the cards. Balances risk better as well.

Offboard the AAVE-A Vault Type - November 15, 2021 - voted YES - at 1M DAI minted from 50M available not being used. Saves us 50K/Q in oracle fees.

Offboard the BAL-A Vault Type - November 15, 2021 - voted YES - underutilized and costing the protocol more in oracle fees than making from SF.

Offboard the COMP-A Vault Type - November 15, 2021 - voted YES costing the protocol more in oracle fees than being made with SF.

Change of Covenants for P1-DROP (Peoples Company Series 1) - November 15, 2021 - voted NO due to already discussed issues. Clean up the legal structures then we can move on DC.

Ratification Poll for Adding Sidestream Auction Services Core Unit, SAS-001 - November 8, 2021 - voted YES Hopefully we will get some more and better liquidation information. I also hope these units co-ordinate data with the CU-Analytics unit.

Ratification Poll for the Immunefi Security Core Unit (IS-001) - November 8, 2021 - voted YES - Agree with PaperImperium that we really need to address budgets and especially MKR compensation allocations to positions that are not filled.

Ratification Poll for Adding the Deco Fixed Rate Core Unit (DECO-001) - November 8, 2021 - voted NO I am for another parallel PECO unit. I have multiple sources telling me that doing tokenized fixed rate derivatives WILL bring us squarely into regulator cross-hairs. My statements for why I am against DECO are above. Bad deal for Maker and a bad precedent as well.

Still deciding on the rest of the polls.


I just stumbled across this via this thread. Good to read a more detailed proposal on a topic that’s been widely discussed on a more abstract level. Some thoughts below, even though I think it’s ultimately @GovAlpha-Core-Unit’s call on how to implement this.

  1. Although the proposed incentive scheme seems simple, in reality I think the actual long-term incentives and outcomes are unknown. It’s an interesting situation from a game-theoretical perspective where the total rewards are static but the Maker governance landscape is dynamic—thus the incentives will be difficult to predict.
  2. If we end up doing this, let’s at least start with a trial for a set amount of months. If we commit to this scheme and somehow the results aren’t satisfactory, I think removing the scheme could lead to critique (again, it’s all about the incentives)
  3. I believe this scheme is subject to a power law dynamic that we’d rather prevent imo. @LongForWisdom mentioned a quadratic tipping trial that sounds like an interesting way to mitigate this.

Delegate Poll/Exec communication 20211120_1102UTC

Poll votes:

Ratification Poll for Modify Core Unit Budget, RWF-001 (MIP40c3-SP39) - November 8, 2021 - voted YES - This is a budget continuation so no actual changes other than MKR vesting to the CU vs. contributors. I agree with @GFXlabs general assessment statement and recommendation regarding changes to how MKR vesting happens. At this time though I don’t see a strong reason to reject the budget modification. If this MKR vesting is not addressed in the next set of budget cycles I will likely change my vote here from Yes to No.

Ratification Poll for Modify Core Unit Budget, COM-001 (MIP40c3-SP40) - November 8, 2021 - voted YES - There is a moderate increase from 486 to 515K (about 6%) pertaining to travel and events. I want to make a comment here that I would rather see a general accounting CU address these budget issues with all CUs within a report so governance can address the global budget more effectively and have some budget quality assurance checking happening. As a delegate or voter micromanaging budgets at this fine grain is both time consuming and annoying. One thing we can see is that accounting errors can be easily made when every CU has to do all of its own internal accounting. I really want to put into place an accounting metric via an accounting CU that all CUs can follow so they don’t have to spend precious resources for their own internal accounting units. I see this happening generally btw, where CUs will spend time gathering their own data vs. using the data analytics unit and I wonder how much time has been spent doing accounting or analytics work vs. specific CU work.

Ratification Poll for the Immunefi Security Core Unit (IS-001) - November 8, 2021 - voted YES - This proposal seeks to add a CU that includes one MakerDAO contributor + Immunefi (a private company) to manage bug bounty program, opsec, and emergency response planning. I agree this appears to take on responsibilities managed by PECO and that anything we can offload from PECO should be helpful to their productivity. I want to re-iterate with respect to MKR compensation to CUs we should be doing this on a per hire level vs. a CU level and these should not be retroactive to empty positions. I voted yes here because I don’t believe now is the use MKR compensation at a CU level vs. hire level to stall addition of CUs. In the future If this does not change I will likely be voting no on budget renewals.

Ratification Poll for Adding Sidestream Auction Services Core Unit, SAS-001 - November 8, 2021 - voted YES - This is a CU with a pretty high price tag. 1.13M annual budget + about 250 MKR worth about 750K at current market price. Even though this is a rather high budget, I know we will need it to retain productive experienced talent. The basic issue as elaborated above is the MKR compensation again is retroactive, and to potentially empty FTEs which needs to be addressed. In general while I am likely to change my view later as these budgets renew I don’t see this as something to stop the addition of needed CUs.

Ratification Poll for Real-World Finance Core Unit MKR Compensation, RWF-001 (MIP40c3-SP38) - November 8, 2021 - voted YES mostly for consistency here. I didn’t want to single out RWF with their MKR compensation from other units. This will change on the next budget requests if these MKR compensation components don’t move away from CU level based to filled FTE requests.

Ratification Poll for Modify Core Unit Budget, MKT-001 (MIP40c3-SP33) - November 8, 2021 - voted YES This is a request for 6 month budget of 425K DAI. Again there are some accounting issues here with respect to clawing back some overbudget that an Accounting CU unit could help address. Hopefully in time we will get this Accounting CU to help smooth over some of the over/under budget inconsistencies and errors in reporting. We are going to need this both on DAI, on the MKR compensation and operations expenses.

Ratification Poll for Supplement to Collateral Onboarding Application (MIP6c3-SP1) - November 8, 2021 - voted YES - Maker has uses a single template for all collateral onboarding applications. This template has not been updated to include RWA. This modification is the first MIP which will include a set of new questions specific to RWA. This is the first of a number of changes and modifications we will need for RWA and I am glad to see them added.

Community Greenlight Poll - SB-frOGI (SolidBlock Red Frog Digital Coin) - November 15, 2021 - voted to Abstain Not entirely sure greenlight polls are useful except to stop protocol work. It is difficult to asses anything about a collateral type before some analysis is made. It would be nice to re-assess how governance greenlight polling. Another general issue on these greenlight polls is that I would like to have statements from all CUs whether and how going forward or stopping a particular greenlight affects them would be helpful.

Community Greenlight Poll - MONETALIS (Monetalis Wholesale SME Green Growth Lending) - November 15, 2021 - voted YES to this greenlight. Comments above regarding greenlighting still apply. I expect this one would still have gone through unless there was a significant no vote to stop it, with the heap of abstains I felt it was important enough to greenlight this to get it to the next stage.

I am going to reiterate an important point here on greenlight polls on anything.
I really want some statement from all CUs on these on whether/how they are affected by these moving forward or not. I am having a hard time grappling with lack of CU statements of position on these and am getting a growing feeling that there are distinct views, opinions and needs going on within CUs that are not propagating up to the governance level. At some point I am going to make a formal poll regarding a request for CU leads to write up some summary report regarding how pushing forward or not on a particular greenlight poll affects them so governance can have some information from Maker CUs before making their own decision.

Current executive:

Onboarding WBTC-B, Increasing WBTC-A Stability Fee, Change of Covenants for P1-DROP, Offboarding Collaterals - November 19, 2021. - supported.

  • I am against DROP modifications
  • the changes in rates wBTC-A going from 2.5 - 4% should give us a good read on pulse of wBTC A users with respect to fees.
  • ilk.hole increases on ETH (A-C), wBTC-A and wsETH-A were well explained.
  • Offboarding of BAL, COMP, AAVE, and changes to offboard LRC-A, BAT-A, ZRX-A, and UNIV2LINKETH-A vaults that are not significantly used will save us oracle fees.
  • Onboarding wBTC-B just confirms my old thesis that multiple vaults on significant collateral types are useful and we can look forward to ETH-D, E, ,etc. and wBTC C, D, E… etc. At some point I expect governance will finally make PSM-A, B, C, D, E which if used with different tin/tout spreads and DCs can by itself create a dynamic PSM spread and fees.

Some color on previous executive.

Parameter Changes, Return Unused Budget to the Surplus Buffer - November 12, 2021 - some more detail on my support of the previous executive.

  • Increasing GUNIV3DAIUSDC-A DC and changes to LR and SF are all reasonable. I expect at some point the competition between PSM tin/tout 0 with this vault will make it less attractive until the PSMs empty and the PEG drops below 1 and then fees will allow this to be utilized more. I do have some concerns that in adverse market conditions the GUNI bots won’t be able to operate effectively rebalancing these v3 vaults. Time will tell.
  • wSTETH-A increase likely will be utilized.
  • D3M increasing the AAVEv2-DAI line - has some hazards but probably a good thing. At some point this should level out. I do find it interesting that with this we can then control external rates thereby allowing a neutralization of rates between Maker and rest of markets helping to modulate liquidity sources/sinks into/out of PSM to deal with impossible trinity rate disparity. Maker also gets additional return using this so finally we can earn return on DAI just by minting and placing it into these protocols.
  • Was happy to see the 218K returned to the surplus, but I think this highlights budget projection and general accounting issues that need to be addressed.

Delegate Poll/Exec communiation 20211122_2150UTC

Poll votes:

Add a GUSD Peg Stability Module - November 22, 2021 - voted Abstain due to fact tin/tout set to 0. I won’t try to block these but won’t be voting for them with tin/tout= 0. I am for PSMs with multiple spreads and DC to effectively hard code a dynamic PSM but the tin/tout values need to be > 0. Already elaborated on hazards of locking the stablecoin markets to 1 through DAI via PSMs with tin/tout=0.

Increase the Aave D3M Maximum Debt Ceiling - November 22, 2021 - voted YES While I think there are significant unintended hazard risks, I believe the potential benefits at this point outweigh those risks. Being able to manage DAI return rates by floating liquidity into these protocols to start reducing return I have felt for a long time was a viable option to managing DAI demand. Governance will need to be able to act quickly on these so if it doesn’t already have it a D3M IAM module might be well considered.

Add WBTC-C as a new Vault Type - November 22, 2021 - voted YES here. Long ago I posited that having multiple vaults with different LR, SF, and DCs would be a useful way to allow users to choose their risk tolerance against fees. Given how Maker is going in this direction I expect to see more of these appear to manage liquidation risks, offer users an even finer grain. With 3rd party solutions such vault ‘stacks’ might offer some unique vault liquidation management strategies and customized rates.

Increase the System Surplus Buffer - November 22, 2021 – voted in order

  1. Increase to 130M by 1M/week
  2. Increase to 90M by 1M/week
  3. Increase to 130M by .67M/week
  4. Increase to 90M by .67M/week

I am a fan of burning because DSSVest is going to mint approximately 7500MKR in the next year for CU MKR compensation so we might as well get buying back the MKR out of the way now while the price is low.

I also calculate that at 127M/yr revenue is 2.44M DAI/week so the minimum DAI slated for MKR burn here will be for almost 1.5M/week. This is still 60% of net DAI revenue. We also grow the surplus at 1M/week so by the time we hit 130M (which will take 70 weeks with this proposal) we will have burned approximately 105M DAI worth of MKR - which even at 5K/MKR would be 21,000MKR or 2.1%

Work done to consider adjustments to the flapper almost always centered around either a 50:50 burn to sb growth or 66:33 burn to SB growth. At above revenue growth we pretty much come in at 60:40 even though we don’t take 1/2 of the MKR going to the burner and save it to fund DSSvest.

In principle Maker governance can ‘by hand’ make MKR CU compensation sustainable simply by allowing MKR to be burned.

With regards to burn model. I think it would be interesting to just let the Surplus Buffer fill indefinitely and to use income from things like D3M to buy MKR to burn. The concept here is to tie MKR burn formally to interest on our accumulated SB. :slight_smile: as this would be totally sustainable and build the surplus buffer as fast as possible.

Right now the surplus buffer is less as a % of outstanding DAI than before Black Thursday I think general consensus is that we should have this be more like 2-5% of our volatile assets (100-250M) given VAs total about 5B.


Delegate Poll/Exec communiation 20211126_1820UTC

Current Executive:

Onboarding New Vault Types, Parameter Changes, and Core Unit Budget Distributions - November 26, 2021 - Supported - the only part of this I don’t support is the tin/tout=0 on GUSD which isn’t sufficient to want to stop this proposal. Going to have to wait a few days after we pay 906K CU expenses and start 10M DAI streaming before we start burning again. The burning run ‘felt good’ and took out over 1.29K MKR in 12 days.

  • The WBTC-C vault type will be onboarded to the Maker Protocol with the parameters below.
  • The GUSD Peg Stability Module will be onboarded to the Maker Protocol with the parameters below.
  • The System Surplus Buffer will be increased to 90 million DAI over a period of 30 weeks.
  • The Aave DAI Direct Deposit Module Maximum Debt Ceiling will be increased from 50 million DAI to 100 million DAI.
  • A total of 906,805 DAI will be transferred to SAS-001, IS-001 and DECO-001 as per their budget proposals.
  • A total of 9,173,516 DAI will be streamed to RWF-001, COM-001 SAS-001, IS-001, MKT-001 and DECO-001 as per their budget proposals.

Going to have to wait a few days after we pay 10M CU expenses before we start burning again.

To clarify, this executive will pay out 906,805 DAI on execution.

The remaining 9,173,516 DAI will be streamed to CUs, over varying lengths of time. So 10 million DAI won’t leave the Surplus Buffer on execution. So while we may wait a few days to replace the 900k DAI, it hopefully won’t be too long a wait to refill the Surplus Buffer.


Delegate Poll/Exec communication 20211130_0456UTC

Increase the Dust Parameter for Most Vault Types - November 29, 2021 - vote Yes dust increases reasonable given gas costs to open/close and liquidate vaults

Increase the Dust Parameter for ETH-B Vault Type - November 29, 2021 - vote Yes again dust increases reasonable given gas costs to open/close and liquidate vaults.

Use the MakerDAO Treasury to Fund MKR Expenses - November 29, 2021 - vote Yes I have discussed in a number of places the idea to connect MKR compensation to DAI earned (net expenses) to make this fully sustainable long term. The basic idea is to take some % of the MKR bought by the flapper and send it to a modified DSSVest.

Add GUNIV3DAIUSDC2-A as a new Vault Type - November 29, 2021 - voted YES to this. Likely rates here will need to be low to compensate for the leveraging going on. Also it will be interesting to see what happens if DAI should drop below 1 and PSMs exhaust. Probably not a huge risk to the system, but more of a risk to the users levering up here.

One Time Payment to the GovComms CU to Deal with Budget Issues - November 29, 2021 - voted YES to this. It is a minor adjustment due to an accounting error after returning surplus funds to surplus. Shows us that a real accounting unit to at least do quality assurance accounting checking is needed. This is also true of the oracle budgets. Honestly would rather have professionals focusing on budget work than each CU having to appoint one person to do their accounting and budgeting.

Parameter Changes Proposal - MakerDAO Open Market Committee - November 29, 2021

Stability Fee Increases

Other Changes

I voted YES as the changes are not unreasonable. I do have some concerns we already have vaults not earning enough income to cover oracles in this list. It is likely some of these may be pushed over the edge with these increases. Also drops in GUNIV3DAIUSDC1-A seems a bit extreme from .5-.1%. I have long supported wBTC because I felt BTC was the prime candidate to mint significant DAI. Here we are over 1B DAI from wBTC alone. Hopefully Maker will add ETH/wBTC D, E, F etc vaults to fill the LR, SF gaps to help spread CRs, potential liquidations, and give users more choices of risk and fees.

Add CurveLP-stETH-ETH as a new Vault Type - November 29, 2021 - voted YES I agree with @rune that Maker probably wants to have these staking vaults. The concern here is that liquidity will fragment as more staking services come on-line and we may not get enough fees to cover the oracle costs as time goes on. But I am willing to take the chance to bring these forward to see if staked ETH becomes the new dominant vault type. What i honestly would like to see is staked ETH paired with DAI v2 LP vaults. But the liquidity isn’t there yet.


Delegate Exec communication 20211206_2232UTC

Parameter Changes, Delegate Compensation, Vault Onboarding - December 3, 2021 ## - Supported

Dust changes.

  • Increase the ETH-B Debt Floor (dust) from 30,000 DAI to 40,000 DAI.
  • Increase the Debt Floor (dust) from 10,000 DAI to 15,000 DAI on all eligible vaults.
  • The full list of which vaults will have their Debt Floor’s changed can be found here.

Onboarding the GUNIV3DAIUSDC2-A Vault Type

As per this successful governance poll, the GUNIV3DAIUSDC2-A vault type will be onboarded to the Maker Protocol with the parameters listed below if this executive proposal passes.

– Initial Collateral Parameters –

** Note that the Debt Floor (dust) value here has been modified to match the outcome of the recent Debt Floor poll.*

– Liquidation Parameters –

Liquidations will be disabled for this collateral type.

Delegate Compensation Payments - November

As per these successful governance polls (1, 2) and the ongoing trial of delegate compensation, a total of 35,834 DAI will be distributed to four recognized delegates as detailed below if this executive proposal passes.

Details on the breakdown of delegate compensation for the month Governance Communications (GOV-001) Core Unit One Time Payment

As per this successful governance poll, a total of 27,058 DAI will be transferred to the Governance Communications Core Unit (COM-001) at 0x1eE3ECa7aEF17D1e74eD7C447CcBA61aC76aDbA9 if this executive proposal passes. of November can be found on the MakerDAO forum here.

Pretty much support most of the above.

I think the GUNI-A vault won’t be sustainable at 1% - time will tell.

Some of the rate changes will probably push vaults into the eliminate category. MANA, UNI. It would be nice when people make vaults at least on oasis a feature to add an e-mail or some contact so people can have ‘a chance’ of being informed of changes to their vaults to be able to take action.

Lastly. Regarding Delegate compensation. Shut my mouth during the CC and have pretty much remained silent until this post on the issue of governance compensation, Delegate or Otherwise.
There are so many points to be made here:

  • One would think compensation for performance would be coupled. My voting performance 100% over the November period.
  • The vote coupling formally the 90/90 performance for the compensation was not voted on until end of October and this was the prime reason compensation IS only for November and not going back to october.
  • There is no formal definition of the performance metric (what time period this covers).
  • The performance level being binary or having curves that just drop to 0 anywhere is arbitrary.
  • The idea only delegates get compensated and no-one else voting in governance seems extreme and unfair to everyone else (shadow delegates and others) generally.
  • There is no distinction between executive support or poll at all with these performance metrics.

I have elaborated two alternative approaches to governance compensation (one posted formally and the other here because I had hoped to get some basic comments from GovAlpha and a few others). It is my impression rather than launch some MIP on the community for approval/disapproval to try to get some pre-MIP discussion going first.


There are a number of other discussions around this topic too numerous to list. Key take away points here is that at no point was there a real discussion regarding the actual goals and the many different ways to achieve them.

  • Why delegates should be treated differently in governance vs. all other participants.
  • What are the tangible/measurable goveranance goals and how to achieve them.
  • Button pushers who may not own one MKR deciding things for those who do own MKR, just to get executives passed, or what?
  • Getting more participation and input via any other models, snapshot polling of MKR, vaults, DAI holders.
  • What was historical participation?
  • Information/report regarding current MKR holders, delegating or not, voting or not.

There also has been minimal discussion about how delegates ‘self elect’, nor time periods or mechanics to garner support, much less any discussion about the significant disparity in MKR delegated and not just how this affects compensation, but also how it affects governance.

Put simply there are basically now 2-3 key delegates with lions share of the MKR delgated and everyone else in governance falls in the wash. I have to wonder will @monet-supply who has 75% voting record - even if he voted 100% in the next 2 months would feel still not earning any compensation. Or worse a shadow delegate who might vote near 100% with 5-10K MKR (I don’t think these are, but how would we know? GovAlpha pretty much ignoring anyone other than delegates in their governance computations, much less give a historical governance perspective).

I know @LongForWisdom was not happy with the outcome that I wouldn’t be compensated in November, and guess what I also won’t be compensated for December because 1 executive vote isn’t going to be enough to push me over. Even though I had 100% participation after a family event that put my wife in the hospital that caused me to miss an executive and 7-8 polls. I honestly don’t remember the details other than some polls only run from Monday to Thursday and if you miss them you miss them. So if someone starts off as a delegate and missed (for any reason) they pretty much are hosed for one or more months until they get their ‘lifetime’ numbers up. Yet someone who happened to start off and do 11 months 100% pretty much could take the last month off and still collect full compensation and since everything only runs 12 months, rinse and repeat the above.

There is no concept of vacation, of illness, or anything else that goes with a normal job considered in these ‘performance metrics’ and in that sense and so many others (with respect to other governance players) are unfair, and inequitable.

I find a general theme with Maker as a broad brush hard, and let the outliers lay when it comes to everything. Rather than focus on providing choices and consequences, do what is simplest from a smart contract perspective or what is easiest… There is this general impression to ignore any other sides of anything, stakeholders included. Vault holders have zero say unless they hold MKR, or participate in forums on anything, same with DAI holders. I suggested long ago to offer a DAI reward to vault holders to answer some polling questions, same with DAI holders. To be sure there is a lot to do at Maker, but each action or inaction by Maker has implications, not just on other communities, but on people and based on the above when changes are made or systems put into place I would like some group, some CU to take on the responsibility of looking at such changes from all stakeholder perspectives.

Frankly I have grown tired of trying to remind this community that its actions have a broader affect and scope than just MKR holders and when I put my vote down to support delegate compensation, while being left out of this, it just tells me do less not more. I think @PaperImperium distinctly felt this and many, many others who probably ‘took it like a man’ and haven’t said a word, some who are still working in CUs, and others who basically have left Maker.

It is my hope that in time MakerDAO grows more sophisticated and empathic about the entire community and not just focus its vision myopically on MKR holders.

For now I am done with this topic, and going to take a general break from thinking and working on Maker ideas and enjoy the holiday times with my family, my coworkers and wish everyone,

  • MKR holders
  • Maker workers
  • Maker Delegates
  • Maker Vault owners
  • DAI holders
  • the entire Defi crypto ecosystem(s)
  • and the world

A Merry Christmas, and Happy New Year.

Let us all hope, affirm and pray (whatever you do) for a 2022 that is better financially, personally, and communally for us all.


Delegate Poll communication 20211207_2012UTC:

Community Greenlight Poll - G-UNIv3-DAIUSDP (Gelato UniswapV3 DAI-USDP LP Token) - December 06, 2021 - YES There is a general personal feeling this vault won’t be good for holders and we will be reducing SF on this in short order to help float this vault. The concern here is what happens to these vault users should the DAI PEG break 1 by any substantial amount for any length of time particularly with the high leverage being applied.

Community Greenlight Poll - aUST (Anchor TerraUSD) - December 06, 2021 - NO I have had my own experience on Terra network and I agree with analysis by @monet-supply [aUST] MIP6 aUST Collateral Onboarding Application - #7 by monet-supply regarding the higher than normal risk. With rather low liquidity and price volatility I don’t believe aUST is mature or robust enough from a risk perspective.

Adjust MATIC-A System Parameters - December 06, 2021 - YES I very much want to support Polygon ecosystem as I feel like out of the many of the available sidechains that they have the most robust activity and growth. The high MC of polygon (now almost 24B) means there is significant TVL that can be locked and a number of significant opportunities for both Maker and Polygon to build more DAI liquidity and availability on Polygon.

Adjust wstETH-A System Parameters - December 06, 2021 - YES Seems like a pretty steep DC increase 50-200M so there is ‘some’ concern over added system risks but it is hard to see how this could be such a big issue other than further concentrating a very high ETH portfolio component by some moderate amount. Maker will have to pay more attention to composition of vault holder activities illustrated here Borrowers concentration analysis

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Delegate Executive communication 20211211_1235UTC:

Parameter Changes, Switching MKR Vesting Source - December 10, 2021 – Supported

Please review the discussion thread to help inform your position before voting.

MATIC-A Parameter Changes

As per this successful governance poll, the following MATIC-A parameters will be updated if this executive proposal passes.

Please review the discussion thread to help inform your position before voting.

Replacing MKR Vesting Streams

As per this successful governance poll, the following MKR vesting streams will be canceled and replaced by streams funded by the Protocol Treasury (Pause Proxy) if this executive proposal passes.

1,051.25 MKR will be streamed to the Oracles Core Unit (ORA-001) starting July 1, 2021 through July 1, 2022 at 0x2d09B7b95f3F312ba6dDfB77bA6971786c5b50Cf in accordance with their active budget proposal. A 1-year cliff is in place, making MKR claimable on July 1, 2022.

803.18 MKR will be streamed to the Growth Core Unit (GRO-001) starting July 1, 2021 through July 1, 2022 at 0x7800C137A645c07132886539217ce192b9F0528e in accordance with their active MKR budget proposal. A 1-year cliff is in place, making MKR claimable on July 1, 2022.

13,930 MKR total will be streamed to 14 team members of the Protocol Engineering Core Unit (PE-001) as detailed below, in accordance with their active budget proposal. All team members have a 1-year cliff and will have their 995 MKR streamed over 4 years.

Nothing out of line with the above so I supported this. I really would like to have MKR flapped connected to MKR rewards so this fully sustainable long term. Fortunately the flapper has been active buying and burning (so far 3K MKR) so after another 6 months we might have burnt the MKR being vested from this executive.


Governance Poll Communicaiton 20211215_1148UTC

DAI Direct Deposit Module (D3M) Debt Ceiling Targeting - December 13, 2021 - RCV

Voted 25%, 30% risk suggests 10-15% rather than vote neither went for the smallest allowed in the vote.

DAI Direct Deposit Module (D3M) Net Rates Spread - December 13, 2021 - YES I have some concerns here, but MakerDAO can reverse course should any of my concerns below manifest.

Comments about D3M with AAVE related to both the above votes.

The biggest issue here to my mind is that while we would like to source DAI through AAVE that inflation across the 3rd world is at 30-40 year highs and so rates will have to rise. Also given Maker has been raising rates if via D3M we make borrowing more attractive than Maker on AAVE we basically will be killing our own business to enhance AAVE which is probably a good reason to hold the stkAAVE and to watch this carefully… People seem to believe that AAVE like MKR will back the system when it fails. @LongForWisdom rightly reminded people that during BlackThursday MKR price went from $600-200 (66% MC drop) and I will add MKR flop auctions had to be halted for roughly a week before auction bidders could be located and the 6M DAI liquidity sourced before the MKR flop auctions could be successfully reenstated selling MKR at 250-280. Should we have a more significant loss event AAVE may not be able to source sufficient liquidity. This would apply to both AAVE and then quite possibly should Maker not have a sufficient Surplus Buffer to MKR…

Recognised Delegate Compensation Trial Performance Modifier - December 13, 2021 - supported with YES

I don’t like voting on delegate compensation generally due to conflict of interest issues, but even if I wasn’t a delegate I would be supporting these. I do think MakerDAO needs to adopt a different compensation model which rewards all governance MKR equally and fairly based on a poll and executive bounty model suggested above in my platform. Then rewards are automatically based on performance and are tied linearly to the MKR voted, delegates getting a 50% pass through reward get compensation based on the amount of MKR they vote. This would lower my own compensation btw but I think it solves various issues around arbitrary performance metrics. Any alternative I believe should be based on a delegate election model and all delegates elected then should receive the same compensation no matter how much MKR they vote as all time and opinions then are equally valued. This 10K MKR as the compensation value cutoff is also arbitrary and has no real performance averaging or buffer for delegates to achieve.

My point here is if MakerDAO is going to compensate delegates it should do it via a model that is fair and equitable either by rewarding MKR based on poll, executive bounties, or equally by forcing all delegates to pass through some sort of election cycle and then no matter how much MKR is delegated to them get equal pay. The idea that governance representatives should get compensated based on their constituency is almost absurd and leads to all kinds of governance abuses and forms of control (I will take your MKR away if you don’t vote this way) that MakerDAO in the future may wish to eliminate. To be sure there are complex issues to deal with in any form of governance, but the arbitrary nature of the structure of delegation as well as compensation I believe is not optimal. As people like to echo here (I disagree with this btw) better to start with something than nothing. This is a test, even if I wasn’t a delegate I would be voting yes, and governance can change this model AT ANY TIME.


Governance Poll Communication 20220112_1616UTC

Prioritize Onboarding a Compound DAI Direct Deposit Module (D3M) - January 10, 2022 - YES - I personally understand compound much better than Maple here and I would prefer to take these on one at a time. Honestly I am thinking we should also consider a USDC D3M module to attempt to normalize rates on both DAI and USDC across the space but this is a separate topic. Given we have other PSMs we also could look at managing stablecoin borrow rates across the larger players in DeFI. Of interest here would be a good look at rates on L2s and possibly sidechains as the costs and liquidity needed may be more manageable. The idea of duplicating Maker functionality on L2 and potentially sidechains is attractive (with my previous caveats) mostly because fees on a number of these networks is so much lower. Issues with sidechains is security but honestly if Maker were to commit to putting up presences on these and connecting them together UI wise (like sushiswap has done) this may actually give Maker a model to ‘serve the underserved’ again vs. what it is becoming (serving the whales, institutional players which has pros/cons).

Raise the Emergency Shutdown Module (ESM) Threshold - January 10, 2022 - voted YES - I stand by my comments here that GovAlpha has done nothing to test and characterize response. There also has been no discussion regarding the potential negative affects a Maker ES would have to Maker, and DeFI in general. Many people do not realize that the Emergency Shutdown is a forced repay of all DAI, withdrawal of collateral, and a restart of an entirely new system with DAI2 vs. DAI1, etc. The implications here are significant. I had hope to write up a post with a Poll on this issue to determine whether we still actually want the ES as an option or whether Maker and DAI are so integrated with DeFI that MakerDAO needs to come up with alternative models to ‘pause’ and then ‘restart’ Maker.

Prioritize DAI Direct Deposit Module (D3M) for Maple Finance - January 10, 2022 - Abstained here mostly because I don’t have a clear understanding of Maple. Will defer to others in absence of information.

Increase the Dust Parameter for Select LP Token Vaults - January 10, 2022 - Voted YES here. I am personally a UNIV2ETHUSDC vault user and I think the dust increase from 15K to 60K is pretty extreme when compared to the 15-25K on what UNIETH etc. It is not entirely clear to me the reasoning here especially with the 15-25K. At some point Maker is going to pretty much clear the decks for any small Maker users on L1.

FYI: My own data suggests that uniswap v2 TOKEN-STABLECOIN vaults actually have much better return characteristics (almost 2x in many cases) than TOKEN-ETH and this is due to almost zero correlation (or even slightly anti-correlation) of STABLECOIN prices to TOKEN prices.

Proposal - Recover DAI Locked in Optimism Escrow - January 10, 2022 - Abstained - I really don’t want to deal with these in a one off mode. I would rather governance deal with this with a policy. Remember every one of us using blockchain has been warned or learned at one time or another - you send funds to a non-recoverable address your funds are gone. I believe we need global refund criterion and a handling/punishment fee here to warn people using DAI (just like any TOKEN screw up at real hazard). If they had sent this to a dead address would these people be asking us for 10M DAI gift to cover their loss (because the funds were lost)?

The rest of these polls I simply put in a placeholder vote as how I see these now these polls run another 2 weeks… With more information I may be willing to change my mind

Community Greenlight Poll - OGN (Origin Protocol) - January 10, 2022 - NO simply because Maker has offboarded higher liquidity and better distribution tokens due to inability to cover oracle fees.

Community Greenlight Poll - OUSD (Origin Dollar) - January 10, 2022 - NO same as above. The idea of the promise of 100M deposited while may be appealing takes away from the limited liquidity elsewhere. in OGN this gets even worse. This would put Maker as being a primary token holder. This ecosystem just isn’t large enough both from a user perspective as well as a liquidity one at least not to function organically and from an institutional level one just seems to risky for the limited rewards.

Community Greenlight Poll - RBLD (Robinland Holdings) - January 10, 2022 - Voted NO - my impression here is that this is just too new. I have a number of concerns over tokenized RE. The primary one is that at least in the US only Reg D investors can hold these which means any sort of liquidation will have limited players. Honestly I am back to a basic issue on RWA MIP6’s. In the absence of tangible information I don’t believe governance can make an informed decision about whether to move forward.

Community Greenlight Poll - TUSD-PSM (TrueUSD) - January 10, 2022 - Abstained here. My tendency is to approve this for green light and to get reports from CUs. It is unclear whether TUSD will bring any real liquidity to DAI nor whether we want to onboard more of these. If you are believer in the PSM model for PEG management you want more. My attitude is that the PSM model of PEG management ‘in time’ will be found not to be sustainable. Worse the 0 fees on both sides of this trade pretty much price fix all PSM stablecoin prices to each other. This is the worst form of price fixing and if ANY SINGLE stablecoin in the Maker PSM umbrella is affected the risk will be the entire DC to the surplus. Also this kind of price fixing, and market monopolistic tendencies usually are not looked at well by various regulatory agencies. If there is a problem rest assured regulators will be taking a very hard look at Maker policies in creating the hazard.

Community Greenlight Poll - USDap (BondAppetit) - January 10, 2022 - NO - This whole 100% LR with low SF is pretty much a risk hazard with no real reward. Again on these RW MIP6s my tendency is to abstain and suggest to CUs/MakerDAO to come up with a better model to pre-filter these MIP6s and to add CU co-authors/sponsors so we know these have at least passed a cursory level scrutiny before being forwarded to governance.

Ratification Poll for Modify Core Unit Budget, ORA-001 (Oracle Gas Costs) (MIP40c3-SP45) - January 10, 2022 - Abstain - I honestly wanted to vote NO mostly because of this 3M claiming to be owed to ‘the Foundation’ which doesn’t exist and existed solely to pay for these expenses. I have serious issues with lack of financial reports from the foundation ‘of any kind’ and the black box the non-profit Foundation was in terms of legal and financial structure. For all we know those who owned the top level for profit the Foundation was under could be walking with 10-20-100M in assets and without any report or even the remotest look, we simply take statements ‘on faith’. The fact these same people gave MakerDAO 84K MKR and then had the audacity to ask for 3M in oracle costs suggests people in that group can’t do decent accounting. I still to this day don’t know what was ‘borrowed’ ETH or DAI or some combination, nor when this happened. This is not what transparency is about. I am completely for covering forward Oracle expenses, in fact I think the emergency fund is low and Maker should completely rethink taking cash and buying ETH and pairing it with USDC to generate return. If the price of ETH drops we end up with more ETH, if it rises we make USDC and lose a little ETH, but over time this UNIV2ETHUSDC generates about .08-.1%/day returns. Also Oracles could actually use the UNIV2ETHUSDC Maker vault to borrow DAI and lever this up increasing the returns by 2-2.5x (from 25 to 50+%/yr). In the end analysis I decided to tentatively abstain and let others decide this one way or another.

Ratification Poll for Onboarding Tech-Ops Core Unit (TECH-001) - January 10, 2022 - Voted YES - Observations from a current 24/7/365 operations specialist that worked as a freelance consult and/or operations specialist in various capacities in operations directly for now almost 30 years now. The 9 FTEs might be sufficient for 1 man 24/7/365 coverage with gaps, and companies with < 1K/hr revenues, but most companies earning > 10K/hr had at least 2 man deep operations coverage because 1 single outage event could cost them between 100-500K and affect business generally. I also found interesting statements about what this group ‘will not’ do when taken in the context of experience that operations tends to be the dumping ground for all enterprise issues. When I sat in hiring rounds for operations group leaders what we wanted to hear from prospective hires was “l will do everything required to satisfy operational goals as long as properly funded and staffed” not “What I won’t do.” Operations is a ‘above and beyond’ type of dirty business, not a pick and choose clean business.

Ratification Poll for the Strategic Finance Core Unit (SF-001) - January 10, 2022 - voted YES - Will add more informed comments later. My impression is that this is more of an accounting and quality assurance group. Unclear to me how this fits but we definitely need a peripheral group looking at Maker overall and providing reports. I honestly would like to see this group work as a delegate MakerDAO research and report arm.

Ratification Poll for Collateral Offboarding Process (MIP62) - January 10, 2022 - YES - The hardest part of any organization isn’t on-boarding people but off-boarding them. I would like to see some standardization of criterion for offboarding than just someone deciding one or more people/CUs need to be offboarded. I would like to see these have some form of complain/appeal system before they even get to governance as everyone in a job can’t just be fired without cause unless they are in a probationary period. Which itself should be considered for new CUs (at least a 1 year probation period where any individual or CU can be offboarded without cause. This forces people to be on their best behavior for at least a year and after that then some real cause needs to be made to remove someone - even if this is a budgetary thing). There are real manpower psychological issues here that need to be considered (how these approaches will affect hiring, or removing). I consider this to be one of the greatest challenges of all DAOs to be considered and tailored with care. This MIP at least is a start.

Ratification Poll for Core Unit Budget, SNE-001 (MIP40c3-SP47) - January 10, 2022 - Voted YES.

Ratification Poll for Bug Bounty Program for MakerDAO Critical Infrastructure (MIP64) - January 10, 2022 - YES - Required to fund bounty programs.

Ratification Poll for Maker Keeper Network (MIP63) - January 10, 2022 - YES - MakerDAO definitely needs to work on improving the keeper network.

Ratification Poll for Offboarding Content Production Core Unit (MKT-001) - January 10, 2022 - ABSTAIN - As one who has friends and peripherially worked in media production in the past I realize that 6 months probably isn’t a fair look at what this group can accomplish. Willing to give this group more time here but not enough to vote NO. Put simply I don’t feel like I have enough objective information to make a call one way or another here in such a short period.

Ratification Poll for Facilitator Onboarding for RWF-001 (MIP41c4-SP27) - January 10, 2022 - Voted YES. I have some conflict of interest concerns and can’t speak for Will myself but trust @rune with respect to judgement. I honestly feel Maker would be well suited to continue looking for someone who wants this position long term.

Ratification Poll for Development & UX Core Unit Budget - DUX-001 (MIP40c3-SP52) - January 10, 2022 - Voted YES.

Ratification Poll for Modify Core Unit Budget - Sustainable Ecosystem Scaling (SES-001) (MIP40c3-SP55) - January 10, 2022 - Voted YES

Some general CU budget comments: I have some issues with how these budgets are evolving and lack of any KPIs being applied. For the time being Maker has funds, at some point in the future we may not and when choosing between minting and selling MKR to cover expenses or tightening the belt it will not be pleasant time. I hope CUs keep this in mind when managing budget requests. It is nice to see some caps being applied and hope to see more of this in the future.


Hi MakerMan,

Thanks so much for your feedback! I’m Scarlet Chen, Robinland’s CEO, and I’m here to answer any question you might have. I wanted to clarify 2 things:

  1. Security tokens does not mean Reg D. Reg A allows any US non accredited investor to invest and Reg S allows non-US investors to invest. CeresCoin is a recent case where a crypto company was approved by the SEC to issue a Reg A fund.
  2. More importantly, retail investors are not involved in any stage of the process that Robinland is proposing. After tokenization of the real estate debt asset, Robinland will not sell the tokens to retail investors, but will pledge them entirely to Maker to access financing. In other words, all that Robinland does is a transformation of RWA into on-chain collateral, such that developers can access financing from Defi lenders to build a more sustainable physical world. This is actually an advantage of our proposal compared to other ones where retail investors are involved, because when there is no retail investor, compliance risk is minimal.
  3. This might bring question of ‘what happens if Maker wants to sell these security tokens’. In fact, MonetSupply has asked that question on his delegate platform and we’ve addressed it there. We’ve also posted the reply to our proposal.

Hope that this addresses your concern, and we’re happy to answer any other question you or the community might have!

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I’m not sure that the feedback is relevant for these particular proposals.

They explicitly do not ask for an increase in the budget. In fact they’re made precisely to accommodate the concerns that you’re mentioning.


Probably right. I should just put a separate sections with general budget comments. Appreciate the catch and feed back here.


This is the part that puts pretty high risk exclusively on Maker. I share similar concerns with @monet-supply regarding liquidation or this put option. The point here is that it is not clear Robinland will be able to source liquidity ‘at price’ to for these positions to be exited should markets shift against Robinland.

It is not clear that the proposed structure scales well, nor who is going to be responsible for the independent auditing of the state of this tokenized bundled RE portfolio being built nor who sits with what assets as the first investors to lose should the value of this portfolio come under market pressure My concern is that there isn’t sufficient investment buffer to mitigate the significant and exclusive risk being presented to Maker. I also have concerns about Robinland being in charge of the liquidations presenting a conflict of interest hazard.

The point here is that in your reply you say:

Yet Robinland is not going to sell one token to these investors, nor does it look like Robinland is going to allow markets to develop to trade these tokens enabling both a token pricing oracle to be created, as well as a market to liquidate them into. I don’t understand how there is benefit to tokenizing real estate portfolios (or even individual issues) if one isn’t going to allow 3rd party markets to form to trade these. In effect your company is complicating the what could be a more straight forward Arranger model and legal structure by tokenizing vs. simply presenting the portfolio to first some investor group for initial financing (to provide the loss buffer beyond this 90% LTV being proposed) and to approach Maker and other investors to pick up the rest there by diversifying the risk to multiple investor layers structured appropriately with reward against the risk taken.

Hence my opinion here is the structure of the Robinland isn’t mature enough (in your proposal said you are still working on legal details), there isn’t sufficient investor diversification, and there is a over complication regarding tokenizing which would be useful when looking to seek investors in the crypto DeFI space, but not so useful if your company is going to offload 100% of these tokens on to Maker. When I heap on that Robinland is also the liquidator this particular proposal looks to be significantly outside not just of the risk profile Maker wants to take on, but also will not be able to support the Stablity Fee that would be required to mitigate these pretty extreme risks.

I would be much more interested if Robinland was more mature, had robust trading markets and large Market Cap and already had investors on board at various risk levels in front of the token holders here and would encourage Robinland to come back when the RBLD token and your business is more established. Alternatively consider working a different structure than tokenizing as this is not required for Maker to be able to take on real world assets.

This proposal honestly looks more like a solicitation for exclusive investment vs. establishing a borrow facility and Maker holding most if not all of these tokens is only going to earn SF and not get a return via RBLD tokens for making this investment. So in the loosest sense Robinland gets all the upside while Maker takes on all the investment risk and Robinland sits not just as the presenter, manager of this business but also the liquidation manager.