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                              January 29, 2024

       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. 4 to
                                                            Offering Statement
on Form 1-A
                                                            Filed January 12,
2024
                                                            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. 4 to Offering Statement on Form 1-A

       Operations - Administrative Services Agreement with Compound
Administrative, page 44

   1.                                                   Please refer to prior
comment 4. Since you initially entered into the Administrative
                                                        Services Agreement with
Compound Administrative Services LLC (   CAS   ) on March 17,
                                                        2022, please tell us
and revise your filing to clearly disclose if CAS incurred any expenses
                                                        on your behalf during
the year ended December 31, 2022 along with an explanation of
                                                        where these expenses
are reflected in your financial statements, if applicable.
       Exhibits

   2.                                                   We note your statement
on page 44 that you amended the Administrative Services
                                                        Agreement on January
12, 2024. Please file the amendment as an exhibit to this offering
                                                        statement. Refer to
Item 17 of Form 1-A.

              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
 Inderjit Tuli
Compound Real Estate Bonds, Inc.
January 29, 2024
Page 2

FINRA advise us that it has no objections to the compensation arrangements
prior to
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,
FirstName LastNameInderjit Tuli
                                                           Division of
Corporation Finance
Comapany NameCompound Real Estate Bonds, Inc.
                                                           Office of Finance
January 29, 2024 Page 2
cc:       Arden Anderson, Esq.
FirstName LastName