Document Verification Policy

Documents required before a project can be reviewed

• Certificate of Occupancy (C-of-O) or Right of Occupancy (R-of-O)
• Complete deed of assignment chain (if developer is not original grantee)
• Survey plan, signed by a Surveyor-General-registered surveyor
• Encumbrance search certificate (≤ 90 days old)
• CAC certificate of incorporation + most recent annual return
• CAC Memorandum & Articles of Association
• CAC particulars of directors + persons with significant control
• Tax Identification Number certificate + most recent Tax Clearance
• Building permit / planning approval
• Source-of-funds disclosure (form provided by platform)
• For SEC-thresholded offerings: SEC registration certificate +

registered fund manager engagement letter

Verification standard

For each document, the assigned Legal reviewer must:

1. Authenticate against the issuing authority (cross-reference number,

date, grantee, etc.).

1. Confirm currency (not expired, not revoked).
2. Confirm consistency with the offering materials.
3. Capture a SHA-256 fingerprint of the document file.
4. Record the verification outcome, the authority reference, and the

verification date in the audit log.

Document fingerprinting

Once a document is verified, its SHA-256 hash is locked. If the developer later replaces the file, the hash mismatch will:

1. Automatically revoke the project's Legal clearance.
2. Notify the original reviewer + Head of Legal.
3. Move the project back to pending_legal_review.
4. Notify all investors who have already committed.

This is non-negotiable and applies to every document in the verification record.

Re-verification triggers

Even without a file swap, re-verification is triggered when:

• C-of-O is more than 180 days from last verification.
• CAC annual return becomes due.
• Tax Clearance expires.
• Building permit expires or is amended.
• A material change is made to project scope.

Document handling

All documents are stored encrypted at rest using AES-256-GCM envelope encryption (see Data Protection Policy). Access is logged; reviewers see documents on-screen and cannot download. Documents are retained for 7 years after project completion, then purged in line with NDPA / NDPR.