I just saw something quite interesting. DeLin Holdings' RWA tokenization business recently received a "No Further Comments" from the Hong Kong Securities and Futures Commission. This is not an ordinary compliance green light; it’s the first time Hong Kong has successfully established a replicable RWA business chain.

In the past, the RWA industry was all about concept promotion; this time is different—it's truly running a complete licensed financial process. Assets are first placed into a limited partnership fund, managed by a licensed asset management institution, then distributed to professional investors through licensed brokerages, and finally, blockchain is used for share registration. To put it simply, what’s on the chain are not houses or equity, but fund shares.

The most critical point here has been overlooked by many. Many think RWA is about directly moving assets onto the chain, but it’s actually the opposite. The logic of this structure is: assets must first enter the licensed financial system and become regulated securities before blockchain can serve as its ledger. In other words, this is about making the chain part of the financial system, not about assets escaping from it.

Limited partnership funds play a key role here, but they solve not a technical problem but a legal one. Real-world assets cannot be transferred directly via blockchain; real estate still needs to be registered with the land registry, and equity still needs confirmation from the company registration office. The fund structure provides a securitized container that can be split, allocated, and transferred; investors hold fund shares, the fund holds the underlying assets, and tokenization is simply moving the registration from traditional systems onto the chain.

A detail worth noting: this structure doesn’t include a Virtual Asset Trading Platform (VATP) or any secondary market trading arrangements. Why? Because current RWAs are still primary market products; all issuance, subscription, holding, and redemption are completed within the licensed institution system. Without standardized products, market makers, or continuous pricing capabilities, exchanges cannot connect.

Tokenized fund shares are essentially unlisted securities; due to their complexity and limited liquidity, they can currently only target professional investors. To truly reach retail markets, three conditions must be met simultaneously: standardized product formats, compliant secondary markets, and a complete custody and settlement system. Until these infrastructures are in place, RWA can only operate within the circle of institutional investors.

The significance of this path lies in breaking the previous technical misconceptions. Whether RWA can succeed depends not on how powerful a public chain is, but on whether the legal structure is complete. Hong Kong’s approach this time is to apply the existing regulatory framework—using the same requirements—onto distributed ledgers, pushing the boundary of the business outward.

Once the ledger is rewritten, liquidity, trading scenarios, and retail markets will follow in turn. But that’s a matter for the next stage.