Trusted Information Infrastructure for Institutional Real Estate Finance
Executive Summary Private markets are entering a period in which the quality, availability, and verifiability of underlying asset information are increasingly consequential to financial institutions. Regulatory scrutiny of private asset valuations, expanding insurer disclosure requirements, and new assurance frameworks for digital assets reinforce a common principle: financial instruments must be supported by reliable evidence of the assets, rights, and economic values they represent. The infrastructure required to meet these expectations remains fragmented. Property records, financial statements, contracts, collateral information, valuations, and supporting evidence are distributed across owners, lenders, administrators, accountants, and other service providers. Information is repeatedly collected and reconstructed for individual transactions, leaving institutions dependent on periodic reporting, manual reconciliation, and inconsistent data quality. Building Inc. is developing the persistent information infrastructure needed to address this problem. Through Building OS and the Asset Record, property information can be organized, maintained, permissioned, and made available to authorized counterparties throughout the asset's financial lifecycle. Rather than replacing institutional valuation, accounting, or
compliance functions, Building supplies the structured information and evidentiary history upon which those functions depend. This creates a commercial opportunity beyond operational software or tokenization. Institutions holding, financing, securitizing, or distributing real estate-linked instruments require dependable information to support valuation, risk management, investor reporting, and regulatory obligations. The growing demand for this information creates an opportunity for Building to serve as a shared infrastructure layer connecting physical assets to institutional financial markets.
I. The Market Is Moving Toward Verifiable Asset Information Historically, private market information has been assembled episodically. Owners prepare documents for financing, lenders perform underwriting, appraisers establish values, and administrators and auditors reconstruct supporting records during reporting periods. This approach becomes increasingly costly as assets participate in more sophisticated financial structures. A commercial property may simultaneously support a mortgage, a fund investment, a credit facility, a securitized instrument, and other contractual obligations.
Each participant requires information about the same underlying property but may maintain a separate version of its financial and operational condition. The underlying asset is common; the information systems are not. As private assets become more widely held within regulated funds, insurance portfolios, and other institutional structures, this fragmentation becomes a financial and compliance concern. Institutions must support valuations and disclosures with sufficient evidence, even where underlying assets remain illiquid and information is difficult to obtain. The broader transition is from transaction-dependent information collection to persistent, asset-level information infrastructure. Such infrastructure does not eliminate professional judgment, valuation uncertainty, or regulatory obligations. It improves the availability and reliability of the information necessary to fulfill them.
II. Regulatory and Accounting Developments Are Reinforcing Demand Four recent developments illustrate different dimensions of this transition.
SEC: Fair-Value Measurement and Disclosure On September 28, 2026, senior SEC staff issued a statement reinforcing the application of FASB ASC 820 to private asset valuations, particularly private credit. The
statement emphasizes that missing borrower information does not eliminate applicable fair-value obligations, that valuation techniques should consider current market conditions, and that reliance on net asset value must satisfy the applicable accounting requirements. The statement reinforces existing obligations rather than creating a new continuous-valuation mandate. For investment managers, business development companies, and other affected registrants, the practical requirement is a defensible process supported by appropriate information, methodology, controls, and disclosure. Building's relevance: Persistent financial, contractual, and collateral information can reduce the effort required to substantiate valuations, identify material changes, and reconcile asset-level evidence with market assumptions.
NAIC: Private Investment Transparency The National Association of Insurance Commissioners adopted additional reporting requirements affecting insurers' private placements and other investments for 2026 reporting. These include identifying investment classifications and providing greater detail concerning carrying values, fair values, Level 2 and Level 3 measurements, deferred and payment-in-kind interest, and reliance on private letter ratings. These developments increase the importance of accurate classification and
supporting records for complex institutional holdings.
AICPA: Operational Controls and Independent Assurance
Building's relevance: A properly structured Asset Record can connect underlying property information to loans, collateral arrangements, investment positions, and reporting classifications. The classification and accounting treatment themselves remain the responsibility of the institution and its qualified advisers.
In January 2026, the AICPA expanded its stablecoin reporting criteria to include controls supporting ongoing token operations.
GENIUS Act: Reserve Integrity and Digital Settlement The GENIUS Act establishes a federal regulatory framework for payment stablecoins, with its general effective date expected January 18, 2027, subject to the statutory implementation provisions. Its requirements concern permissible reserves, redemption, issuance, and regulatory supervision. Payment stablecoin reserves are subject to specific eligibility requirements; ordinary illiquid real estate and private loans do not become permitted reserves simply because they are tokenized. Nevertheless, the Act advances the development of regulated digital settlement infrastructure. Tokenized investment markets will require reliable settlement instruments alongside reliable representations of underlying investment assets. Building's relevance: Building addresses the asset-information side of this emerging financial architecture, distinct from stablecoin issuance and reserve administration.
The development distinguishes reporting on assets at a specific point in time from evaluating the design and effectiveness of operational controls over a period. These criteria apply specifically to relevant stablecoin reporting and assurance engagements. They nevertheless demonstrate a broader institutional principle: trustworthy financial information depends on repeatable processes, controls, and supporting evidence, not merely a reported balance. Building's relevance: Provenance, reconciliation, change histories, controlled access, and reproducible information flows can support the evidentiary requirements of institutional assurance processes. Taken together, these developments do not establish one universal compliance regime for private assets. They demonstrate converging expectations for transparency, information quality, valuation discipline, and verifiable operational processes.
III. Institutional Requirements Differ from Property Owner Requirements The incentives of a real estate owner and a regulated financial institution are materially different.
A developer primarily requires efficient property operations, financing, construction oversight, and successful execution of the business plan. Regulatory classifications of financial instruments may have limited importance to everyday asset management. A fund manager, insurer, lender, or structured-finance participant faces additional obligations arising from the financial instrument and the institution holding it. Such obligations may include: •
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Valuation: Establishing defensible asset or investment values using appropriate inputs, assumptions, and methodologies. Classification: Identifying the appropriate accounting, regulatory, and contractual treatment of investments and exposures. Collateral monitoring: Evaluating coverage, liens, covenants, performance, and material changes to pledged assets. Reporting: Preparing accurate disclosures for investors, auditors, regulators, and other stakeholders. Independent assurance: Providing evidence that calculations, controls, and reported information can be tested or corroborated. Transaction readiness: Maintaining information sufficient to support financing, transfers, securitization, and potential digital issuance.
The same underlying property information may serve all six functions.
This creates an important distinction in Building's commercial strategy. For property owners, the initial value proposition may center on efficiency, reduced diligence costs, and improved access to financing. For institutional counterparties, it extends to an information infrastructure capable of supporting ongoing financial and regulatory processes. The latter may justify recurring infrastructure expenditures because the value is tied not simply to software utilization but to the continuing management and financial treatment of institutional assets.
IV. The Institutional Information and Verification Architecture A persistent Asset Record creates the foundation for repeated and independently corroborated valuations. The proposed operating model involves several participants with distinct responsibilities. 1. Asset owner or operator Maintains the underlying operating, financial, legal, and collateral information. Source documents remain within authorized systems, with relevant information made available through controlled interfaces. 2. Building — information infrastructure Structures and reconciles asset information, maintains source provenance and change histories, identifies data gaps,
manages permissions, and delivers versioned information to authorized institutions and applications. Building does not need to become the system of record for every source document or assume ownership of the underlying information. 3. Investment manager or lender Determines the relevant investment exposure, reporting obligations, risk policies, collateral requirements, and permissible use of asset information. 4. Independent valuation provider Develops or applies appropriate valuation methodologies, evaluates market assumptions, and produces professional valuations or model outputs within the applicable engagement. 5. Fund administrator and accounting functions Reconcile investment positions, calculations, asset information, and reported values. Independent recalculation or review may provide additional corroboration where appropriate. 6. Auditors, assurance providers, and regulators Review evidence, relevant controls, methodologies, financial statements, and disclosures according to their respective responsibilities and applicable standards. 7. Tokenization platforms, transfer agents, and market infrastructure
Where relevant, connect the financial instrument to issuance, ownership, transfer restrictions, settlement, servicing, and other digital-market processes. The central architectural principle is separation of information infrastructure, valuation judgment, and independent assurance. Building maintains the information foundation. Qualified counterparties perform and validate the relevant financial functions. This separation permits multiple valuation providers and financial institutions to use the same underlying Asset Record without requiring Building to become the proprietary valuation authority. It also supports the development of an interoperable market infrastructure rather than another closed application.
V. From Persistent Information to Independently Corroborated Valuation The financial value of the Asset Record increases as its information is maintained and reused. A practical workflow consists of six stages. Stage 1 — Establish the asset record. Identify the asset, relevant legal entities, ownership interests, financing arrangements, collateral, documents, and operating information. Preserve provenance and the relationship between source evidence and extracted data.
Stage 2 — Establish information quality. Evaluate completeness, recency, consistency, source reliability, and unresolved exceptions against an agreed asset and use-case profile. Record information deficiencies explicitly rather than concealing them within aggregate scores. Stage 3 — Maintain material changes. Capture relevant financial updates, lease events, capital expenditures, financing changes, collateral events, and other inputs affecting institutional analysis. The update frequency should reflect the asset, contractual reporting cycle, and materiality of the information. Stage 4 — Supply approved valuation inputs. Make relevant, versioned information available to approved valuation models and independent providers. Market assumptions, methodology selection,
and valuation judgments remain identifiable and separately controlled. Stage 5 — Corroborate and reconcile. Permit qualified administrators, valuation firms, or assurance providers to reproduce calculations, inspect permissible source evidence, challenge assumptions, and investigate differences. Independent agreement on calculations does not itself prove the economic correctness of a valuation. Stage 6 — Distribute authorized outputs. Supply substantiated information to lenders, investors, auditors, administrators, reporting systems, and, where appropriate.
14 Oct 2026 ・ Building Inc.
References and Source Material 1. U.S. Securities and Exchange Commission (SEC)
Statement on Fair Value Measurement and Disclosure Considerations for Private Assets September 28, 2026 https://www.sec.gov/newsroom/speeches-statements/hohl-daley-statement-fair-value-measurement-disclosure-considerations-private-assets-092806
2. National Association of Insurance Commissioners (NAIC)
Adopted Blanks Reporting Modifications — 2026 Investment Reporting Requirements National Association of Insurance Commissioners, Blanks (E) Working Group https://content.naic.org/cmte_e_app_blanks_related_adopted_mods.htm
3. United States Congress — GENIUS Act
Guiding and Establishing National Innovation for U.S. Stablecoins Act (GENIUS Act) Public Law 119-27, July 18, 2025 Implementation reference: Federal Register, September 30, 2026 https://www.govinfo.gov/content/pkg/FR-2026-09-30/html/2026-19966.htm
4. American Institute of Certified Public Accountants (AICPA)
2025 Criteria for Stablecoin Reporting — Part II: Controls Over Stablecoin Operations January 12, 2026 https://www.aicpa-cima.com/news/article/aicpa-updates-criteria-for-stablecoin-reporting-to-address-controls-over
Foundational Accounting Standard
Financial Accounting Standards Board (FASB) Accounting Standards Codification Topic 820 — Fair Value Measurement https://asc.fasb.org/820