White paper: FEI Lend

Thank you @cozeno for the detailed abstract on this initiative. I trust that the WG members bring breadth and depth of experience. An in-house facility is more effective than relying on integration with others. My comments:

  1. There should be report on development for this facility in regular intervals until realized implementation. Also, the WG and the lending facility as a subsidiary should post monthly balance-sheet reports to the community for transparency in its operations when it is live. There is no proposal on what/how it is run after the implementation period. Will the Founding Group stay on to operate this facility?
  2. This initiative seems to come out of nowhere. Can you please share how this project/WG came into being?
  3. I second that the capital will have to be separate from the PCV, but please suggest how this capital is injected in the first place. Does the PCV and/or Treasury make contributions?
  4. In regards to the TRIBE set aside for external audit, I am confused that you are also proposing an in-house solution for this. Can you please clarify how this fund is to be used if there is no external auditor found?
  5. Please consider a marketing budget and similar marketing operations to raise awareness and utility of this facility. An easy to use interface (or at least perceived as such) is a great positive, and should be similarly documented as such with ‘how-to-use’ and usable from both novice and advanced users.
  6. Is this platform flash-loan friendly?
  7. Is the criteria/standard for security audit in equivalence to the core functions of Fei (they use OZ, among others)? How do you ensure this?
  8. Please establish a dedicated Discord channel (among others) to continue this discussion. I’m sure that a lot of the community would be excited and want to weigh in.

Hello, thank you for your inquires.

  • we will submit biweekly reports on our progress thru development. After its completion, balance sheet reports arent necessary because the protocol’s holdings will be highly transparent at any given time. Given the nature of Defi lending platforms manual maintenance and “operation” is minimal, though further updates to the code will be executed by the multisig guardian. In the long run, as mentioned, there will be an elected executive council taking over from our WG.
  • This initiative started in the Chinese community, and has saw extended discussions there. We have also been in close concert with the team
  • According to Joey, DAO treasury would be the most likely source of funds.
  • “external” auditing refers to the fact that our auditor will stay out of the project until the very end. with regards to auditing standards, we have came up with this in response to the fact that the team’s auditing resources are very stressed and cant spare any more for phase 1 of our project.
  • marketing will be a “phase 2” integration, discord channel will go up when this reaches FIP stage. associated GUI and guides are included as part of the development process.
  • collaterals is a key part of to the security and purpose of this project, flash loans are explicatedly not supported in our first phase.

We will try to publish an ama between FEI core team and our WG. Our WG members will seek to engage with the community more and establish our credentials, though so far our engagements have been overwhelmingly concentrated in the Chinese channels.

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I love the idea, and the team looks solid, I hope that effort can be funded by the DAO.

I’ve talked about “market making” on Aave & other lending platforms to control the lending & borrow rate of FEI before, as I believe it will drive a lot of adoption, but for all the reasons you outlined, having our own lending platform makes sense. We would have FEI / TRIBE there + potentially some of the assets held in the PCV, later on.

I think the DAO should be more generous than 250k TRIBE to this working group, as they are 6, would be building a key infrastructure for the future of the protocol, and they are taking “more risks” as the protocol is still young (so the governance token’s value is yet to be proven). Plus, the DAO is basically taking 0 risk as all TRIBEs would be timelocked & payment is unlocked upon delivery. And they already started working without certainty of getting anything in return.


@cozeno thanks for taking the time to develop this idea with the working group and sharing it with the community so eloquently.

We have always thought of lending as one of the most compelling early use cases for FEI. In fact, the Tetranode lending pool on Rari became one of the first places to deploy FEI productively shortly after the launch. In order to expand the lending use cases, we are also working with Cream and Kashi to get FEI listed on their platforms, and eventually want to get Compound/Aave listings once Fei Protocol is more established.

On top of simply getting listed on other lending platforms, we have also been thinking about how to bootstrap those lending markets and subsidize rates on them. This could be achieved with:

  • A connector that deploys FEI to these markets in order to attract borrow demand, or simply to lower the interest rate while also earning LP fees for Fei Protocol.
  • A connector that borrows ETH against FEI in these markets, which would hedge the protocol against ETH volatility and also increase the interest rate earned on lending FEI to incentivize FEI supply.

With regards to this specific proposal to fork Compound: it is an exciting idea for the future, but it is not clear to me that simpler alternatives (like the connectors listed above) have been properly considered.

For something that is not going to directly help Fei keep a tighter peg, the level of complexity and risk involved in maintaining a Compound fork seems very unreasonable, especially considering the nascent state of Fei Protocol and the simpler alternatives listed above. At this time, developing utility for FEI through integrations and partnerships makes more sense than expanding into adjacent verticals like lending.

For all of the above reasons, we are happy to continue to engage with the Fei Lend working group on simpler alternatives, but are not in support of this proposal at this stage of Fei’s evolution.


Hi, Cozeno! Thank you so much. I’m glad to see the protocol evolving thanks to the likes of you and your team. I agree with your position regarding the implementation of the functions of the protocol in the field of borrowing and lending.

@sebastian , thanks for your insight. Apologies for hijacking this thread, but wanted to ask some questions:

Can you please elaborate ‘subsidized lending rates’? I’m concerned about how the PCV/Treasury will support this endeavor as it will be a liability, unless the LP fees can break even the subsidy rate.

Are these ‘connectors’ similar to whitelisting on Iron Bank (such as with yearn)? Is this a simple way of saying that Fei gets a preferential SOFR/LIBOR rate of lending, or without collateral?

Appreciate your thoughts.

It is unfortunate that there is limited support for the Lending facility, because an in-house implementation would be able to grant us efficiencies within the protocol, but I do get where you are coming from - to keep things as simple as possible, at least at this stage.

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Thanks @arcology, you’re not hijacking at all! We’re here for it.

Can you please elaborate ‘subsidized lending rates’? I’m concerned about how the PCV/Treasury will support this endeavor as it will be a liability, unless the LP fees can break even the subsidy rate

The bullets with the connectors are an example of how to we’d be able to manipulate the interest rates. By supplying a lot of FEI to a market, we’d basically be lowering the borrow rate. By borrowing a lot of ETH from that market, we’d be raising the supply rate.

As far as directly subsidizing supply rates, we are thinking about this idea of “boosting” FEI loans, where the protocol matches some % of FEI supplied by users, effectively increasing their APY. This could be done without creating our own lending protocol but we still need to work on it further before sharing it more broadly. Again, the current focus of the team is on achieving those pre-requisite listings on lending protocols like Cream, Kashi, Compound and Aave.

Are these ‘connectors’ similar to whitelisting on Iron Bank (such as with yearn)? Is this a simple way of saying that Fei gets a preferential SOFR/LIBOR rate of lending, or without collateral?

Neither of the suggestions I made above assume Fei Protocol getting any kind of preferential rate, but open to your ideas on how to get this done. Fei’s PCV is large, so its not unreasonable to think that lending platforms could be open to this type of partnership.

It is unfortunate that there is limited support for the Lending facility

One day Fei Labs and the community as a whole will have the resources to compete with other protocols/communities that are fully dedicated to lending. For now, I think it will be most advantageous to focus on creating The Stablecoin for DeFi, which is a tall order in and of itself.

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Very clever idea. It is an interesting way to hedge ETH risk. If I understand well, we would provide FEI as collateral (minted?) and receive ETH. I just did not understand the impact on the FEI interest rate. If we borrow ETH, the impact would not be in the ETH lending rate?

Thank you for your response!

We have thoroughly examined building a connector vs building a proprietary lending platform, and we are exploring both options, though we still lean towards building an inhouse lending platform, for the following reasons:

  1. A light-weight fork of COMP will consist of roughly 30,000 lines of Solidity code, of which parameter maintenance needs to happen on a roughly month basis if we are to strictly limit ourselves to a handful of assets. Whereas building a interest rate pipeline is probably best achieved through a “cToken” holding smart contract, and per our estimate probably, involves roughly 2000 lines of code per asset per platform. Consider the amount of extra integration and maintenance needed, as the number of platforms rises, the ultimate workload of the latter option may very well approach building from scratch.
  2. We have not independently approached any other lending platforms except for COMP, cream and kashi are two immediate use cases that has been repeatedly mentioned. Though we are open to learning more about these platforms, and devise an ad hoc solution which would facilitate FEI’s control of its own lending rate. Though according to the “interest rate parity theory”, supplying a huge amount of liquidity to a single platform should equalize interest across the entire defi world. whether that platform may be FEI Lend or some other.
  3. A multi-platform connector will expose the deposited funds to hundreds of possible attack vectors; vis-a-vis the recent attack on VENUS, where a group of attackers used around $60-70 Million to pump the governance token XVS, which wasn’t very liquid. After which they deposited all of their XVS at the tip top and borrowed ETH/wBTC and started shorting/dumping XVS resulting in over $100M loss for Venus. This is only a single example of how the hundreds of pairs that are lend/borrowed collectively on those platforms can result in losses unrelated to programming side of things.

Hey ya’ll! Interesting proposal.

If FEI wishes to expand and become adopted through defi, I wholeheartedly agree with the sentiment that liquid lending markets are key.

However, I disagree with the notion that the FEI protocol (especially a group of outsiders) should be maintaining a fork of Compound (or any lending market) on their own.

For context, i’m a leading contributor at Rari Capital and have helped develop and maintain the Fuse open interest rate protocol since inception. Fuse allows anyone to spin up their own isolated lending markets (like Compound or AAVE) and in only 2 months since release it has grown to see as much as $65m supplied across all pools.

Maintaining a fork of the Compound protocol is risky even if the code itself requires little modification.

You need to monitor the system and promptly take action if something suspicious arises or market conditions change, gather a network of robust liquidators, build out administration dashboards to allow governance or the team to modify protocol parameters, build out a robust UI for users to interact with the protocol and continuously adjust to provide the best experience, etc.

The creator of this thread has proposed that an external team (without a known track-record) fork and reaudit the Compound codebase themselves. The creator justifies this fork instead of utilizing an existing protocol like Fuse (which allows anyone to easily create a fork of Compound and has been audited multiple times by reputable firms like Quantstamp) as they believe that other protocols have too much “external risk”.

As a pre-emptive response to doubling down on Rari Capital’s existing Fei/Tribe Fuse Pool (which at it’s peak attracted nearly $15m of capital) the thread creator says that Rari Capital has a “complex” tranche system and “pools all of their stablecoins together”.

This is false and misleading for multiple reasons:

  • Fuse is an entirely isolated system from the rest of Rari Capital’s offerings.
  • Rari Capital’s yield aggregator pools deposit into Fuse but Fuse pools do not deposit or interact with any of Rari Capital’s other products.
  • Each Fuse pool is an entirely isolated instance of Compound and in no way does it “pool all of the stablecoins together”
  • You don’t have to trust me, trust our open open-source code! compound-protocol/contracts at fuse-v1.1.0 · Rari-Capital/compound-protocol · GitHub

The thread creator also says that Rari has suffered from “a lack of liquidity” (which I would argue is untrue, $15m of total supplied at the peak along with nearly $3m borrowed is not insignificant in the slightest).

If you take a look through the FEI discord you will find many users and moderators sharing slideshows and infographics they’ve made with newcomers to allow them to take out complex staking positions (like single sided tribe staking). Fuse has already shown strong product-market-fit with the Fei community and gained their trust.

Even if you disagree that Fuse has already proven it’s value to the Fei community, I don’t see how creating a brand new isolated Compound fork would solve a “lack of liquidity”. By itself a new market would only further fragment liquidity and hurt Fei users. Sending $25m of PCV to this brand new market could help in theory, but these funds could be much better spent if they were put in a battle-tested protocol already trusted by the Fei community.

Sending this PCV to Fuse would allow the existing market to continue to thrive and expand, and combined with a marketing/rewards campaign by the Fei community this would continue to foster a symbiotic relationship between the Rari Capital and Fei community.

Doubling down on Fuse instead of a custom fork has numerous advantages:

  • The FEI DAO can take full advantage of the support and vigilant operational practices the Rari Capital core team have brought with Fuse.
  • The FEI DAO does not need to worry about managing liquidators or finding the right protocol knobs to turn in the event of an emergency. Rari Capital contributors have the deepest knowledge of the Compound protocol besides the original Compound team themselves!
  • The FEI DAO does not need to spend hundreds of thousands of dollars forking and doing an internal audit for a new lending market.
  • Liquidity is not fragmented between multiple lending markets
  • The FEI community benefits from the shared interest and borrowing demand the Rari Capital community generates from using Fuse every day.
  • A beautiful, open source, and battle-tested UI has been available from day one, along with high quality developer/integration documentation coming soon.

All of these advantages come with no compromise in admin flexibility. Pool admins have even more flexibility than standard Compound admins. Fuse admins can do everything a standard Compound admin can along with the ability to set whitelists and take fees. The Fuse protocol does currently have a flat 10% protocol fee on all interest earned, but if the FEI DAO was to deposit PCV and further strengthen the Fuse protocol, I think it would be fairly easy to convince the Rari Capital DAO to exempt or lower the fee for the FEI/TRIBE pool in exchange for the usage and TVL it brings to the platform!

I would argue that Fuse and Rari Capital as a whole have proven ourselves as trusted partners to the Fei community, and this is not just based on sentiment. Would recommend taking a look at the last 15 days of activity on the FEI/TRIBE Fuse Pool here: Grafana (this is another pro of using Fuse, you get to piggyback off of the existing monitoring and analytics tools the community and team have made!)

In the last 15 days Fuse Pool 7 was able to survive a massive TRIBE borrow which led to near 100% utilization at one point and has seen over 281 unique deposits already. There are no insolvencies and the pool has already built up nearly $10k of reserves to prepare for any possible liquidation or system failures.

With all the above in mind, I hope the Fei/Tribe community is skeptical of the idea that an external team without a proven track-record or community trust should be paid to fork Compound for FEI/TRIBE when a proven protocol already used by the FEI community exists and could be further supported and strengthened by the FEI DAO.

Happy to answer any questions the community has about Fuse and/or how the FEI DAO can become more involved with managing the leading FEI/TRIBE lending market!

P.S: Even though I’ve been a critical about some of the details of this proposal in my response, I want to say that I think this idea of using PCV to allow the FEI DAO to set and manage interest rates across a lending market is fantastic, and the other Rari Capital contributors and I would be thrilled to help the thread creator(s) build some abstractions on top of Fuse to make this easy for the FEI DAO :stuck_out_tongue:


Hello t11s - Thank you for your thoughtful response. I second the idea that the Fei and Rari communities have many potential synergies that I would like to see come to fruition!

Instead of working to build and maintain our own Compound fork, we can use the work of other projects, including Rari, to advance toward forward-looking targets of interest rate management and providing liquidity as a DAO.

As we explore options for FEI lending, I suggest we open the discussion with the Rari community about exempting the current Rari platform fee of 10% through a whitelist, and the possibility of switching admin functionality to the Fei DAO. I think it would be worthwhile to further investigate this integration if the Fei DAO has the ability to adjust parameters and receive fees from the Fuse pools.


I suggest we open the discussion with the Rari community about exempting the current Rari platform fee of 10% through a whitelist

Makes sense! Feel free to start a discussion on https://forums.rari.capital or in our discord!

admin functionality to the Fei DAO

This also makes sense to me if the Fei DAO wishes to commit a lot of PCV— it should be in control. The current leading FEI pool is managed by Tetranode, but we are happy to reach out on the Fei DAO’s behalf to negotiate a transfer.

I think it would be worthwhile to further investigate this integration if the Fei DAO has the ability to adjust parameters and receive fees from the Fuse pools.

Absolutely! Some of our other pool admins have already started taking advantage of the insane level of customizability Fuse’s markets bring (such as ChainlinkGod/Tetranode’s pool which disables borrowing of all non-stables in exchange for offering higher LTVs).

We as contributors will be standing by ready to help to make whatever customizations the Fei DAO needs :stuck_out_tongue:


@t11s ,

Thank you for sharing this in our community. I also back the notion of a deeper integration between Fei and Rari.
I am not a technical user, but I have been through some of your documentation for Fuse but ont fully understanding the mechanics. Can you please help to provide an overview of the parameters for your pools (eg, Upgradability, Close Factor, Collateral Factor, Liquidation Incentive, others) so that we can further discuss? Also, if the Pool creator is with Fei DAO, how does this differentiate between the Tetranode pool? Would it need to be sunsetted?

Thank you again for bringing this up for discussion.

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I posted this discussion to the Rari community on their forum for anyone who would like to share their thoughts there as well → FEI Lending Partnership - Rari Governance Forums


Can you please help to provide an overview of the parameters for your pools (eg, Upgradability, Close Factor, Collateral Factor, Liquidation Incentive, others) so that we can further discuss?

All of these are described in the Compound whitepaper or documentation. We’ll be releasing our own docs shortly (preview can be found here: Fuse | Rari Capital) but would currently recommended reading over Compound’s resources directly :sweat_smile:

Thank you all.

To move this process forward, we should discuss the assets and amount of PCV that should be placed into this Rari pool, subject to a community vote. We should have at least:


As the primary components of the pool. However, should we also include other assets, including stables and algostables? For example:

OHM? (and others)

Also, how much of the PCV should we migrate into the fuse pool? This would also be like a diversification exercise, and the size of the pool also depends on what other assets we want to pool this together with. I suggest we migrate no more than 20% of the pool, again based on what actually goes in there. The more diversified, the smaller the pool share (or we set up 2 pools, one which contains the main assets and the second one an ‘experimental’ pool with a larger variety with assets, especially other algostables).

I would be very in favor of working with Olympus Dao. They have just partnered with Frax as well. It is my belief that algorithmic protocols should stick together, apes together strong :wink: a great way to initiate something like this, would be to create a crypto ETF holding all of the different algo coin governance tokens, or algo coins themselves.

  • ohm, tribe, fxs, mkr, luna

We could potentially partner with Indexcoop to list something of the sort.


I am a big supporter of this as a Tribe and RGT holder. Win-win!


This is a great idea! Thank you @cozeno. I would like to see the arriving of the Fei lend earlier.