The use case of my research is a bit complex as below:

A team of developers
1. To build a hybrid platform of traditional stock brokerage [e.g. To trade stocks listed in Singapore Stock Exchange, ETF etc ] + Cryto Exchange [e.g. To trade BTC, ETH etc]
2. The platform obtained license to operate as stock brokers from Singapore Monetary Authority [ similar to SEC in USA]
3. To launch ICO of utility tokens which can be used to offset stock brokerage charges and Cryto Exchange trading fees
4. The ICO tokens are offered as a early bird discount crowd selling of utility tokens
5. The operator of the platform will lower the stock brokerage charges and cryto trading fees based on previous quarter trading volumes and net profit [ i.e. use lesser utility token to offset the same stock brokerage charges and cryto trading fees], it is to reward the loyalty of the customers.
6. The utility tokens is tradeable only on the platform and the price is subject to the demand and supply only.
7. When the demand of the tokens are low, the operator of the platform might choose to buy back portion of the tokens in the open market
8. P2P merchants on the platform offers conversion of BTC/ETH etc to USDT [vice versa] and users can use the USDT to purchase Stock/ETC etc on the platform

Base on the Howey Test:
a. It is a stock brokerage early bird servicing offer, it is not an investment of money
b. It is a common enterprise
c. Expectation of profit is based on the demand and supply of the utility tokens

Even though it doesn't pass the Howey test as per above. I wonder if the above facts might give concerns to MAS/SEC that this tokens might be considered as security tokens. Anyone can offer their comments or thoughts on this?

thanks