Identified document
“Reforma interior parcial y acondicionamientos exteriores de edificación turística”, Avenida Janubio s/n, Urbanización Sun Park, Playa Blanca, Yaiza.
APPARENT AUTHORITY → COMMISSION → PROJECT → VISADO → PUBLIC AND ECONOMIC EFFECTS
Architecture as a documentary node: JDAM, the 2022 visado and the chain beyond the hotel.
This record asks whether architectural documentation may have become —with or without the professional's knowledge, which remains open— a technical-legitimacy layer within a property, insolvency, municipal, tourism, investor, finance, tax, public-support, operational and judicial sequence.
Evidential boundary. No crime, professional breach, falsehood, lack of habilitation, professional coordination or public-authority participation is declared. Documented facts, source statements, Project Sun Rock allegations, inferences and open questions are separated. Each actor requires act-by-act proof.
Institutional status at 20 August 2026. COALZ registered entries 26/008230, 26/008474 and 26/008476; the last was passed to its Board, as were the earlier materials. COAGC placed primary disciplinary competence in Lanzarote, said specified data did not match its records, retained ordinary membership data and reported no Sun Park/MYND documentation. The reviewed record does not establish a merits decision, a formally opened disciplinary case or a later explanation of the discrepancy.
1. The conversion chain requiring verification
Apparent authorityProfessional commissionProject and visadoAdministrative useLater benefit / reliance
The issue is not that architecture coexisted with investment or works. It is whether professional records capable of generating administrative and commercial confidence rested on verified premises concerning client, representation, consent, title and perimeter.
Investigative rule: the later result —opened hotel, registration, finance, support or operation— does not retrospectively validate the authority or perimeter invoked when the commission began, the project was prepared or documentation was filed.
2. The 25 February 2022 professional anchor
Reproduced parties
Declared promoter: Comunidad de Propietarios Sun Park de Playa Blanca. Architect/author: D. José D. Acosta Matos.
Identifiers
Visado 25/02/2022 · Col. no. 21428 · ID e4bd916e483d4a9a8ef742fda7c039de · ref. 22/000036/7800 · reproduced COAGC/2315 field awaiting reconciliation.
What it establishes and what it does not. The reviewed copy establishes the content and identifiers it reproduces and the apparent existence of a commission intended for administrative use. By itself it does not establish valid Community authority, each owner's consent, title over every unit, correspondence between project and works, absence of conflict, later site direction, illegality or liability.
3. Ramifications: not limited to the building or hotel
Property and Community
Private units, common elements, representation, minutes, powers and authority of the declared promoter.
Insolvency and non-estate assets
LPB was the insolvent company; Matkator and third-party perimeters are not absorbed by describing the economic whole as “the hotel”.
Yaiza municipality
File 1748/2022, communication/licensing, technical documentation, inspection, observed works, versions and rectification.
Tourism and Cabildo
Holder, operating undertaking, units, beds, capacity, reopening, registration, inspection and MYND Yaiza operation.
Investment and finance
RICPE, due diligence, conflicts, investor presentation, participating finance, valuations and use of funds.
RIC/REF, idoneidad and incentives
Decree 224/2022, AEAT report, Series F/G, refurbishment expenditure, employment, regional incentives and ERDF where each connection is documented.
Tax and public control
Which technical or economic material was used before AEAT, the Canary Islands Government, Intervención, Audiencia de Cuentas or antifraud bodies.
Operation and identity
Sun Park→MYND transformation, opening, marketing, operator, revenue, branding, digital profiles and third-party reliance.
Judicial and professional evidence
DP 1901/2026, preservation of native files and metadata, professional bodies and traceability of what each custodian received and verified.
No coordinated conduct by “all authorities” is alleged. The testable hypothesis is narrower: different authorities and third parties may have received, assumed or reused documentary inputs produced earlier. Each recipient answers only for its competence, records, knowledge and decisions.
4. Converging professional chronology
The communicated record states that the client used a criminal characterisation and instructed pursuit of “the criminal route against these people”; PwC noted that instruction and later confirmed contact with the Insolvency Administrator. This is not an independent PwC criminal finding or proof of JDAM knowledge or liability.
A conflict/confidentiality check for a possible forensic engagement identified Sun Park, CAM and the Insolvency Administrator; an NDA and possible terms existed. This does not establish that work began, information was improperly transferred or a duty was breached.
Eduardo Sánchez stated publicly: “bueno, nosotros en el despacho… en esa primera inversión… metimos unos cuantos clientes”. The statement appears at 08:08–08:12; project attribution and consequences require separate chronology and records.
The visado is the visible professional point from which to ask when technical work began, who commissioned it, what authority was shown, which properties and rights it covered and where it was later used.
The 2021 source was added to a communication within RSM file NNR4-1025C2F66; COALZ and COAGC received preservation/reasoned-decision communications; DP 1901/2026 is cited only as an identifiable judicial traceability route.
5. Two Spanish visual indexes
6. Colleges: territorial competence without a documentary blind spot
| Date / reference | Documented event | What it does not mean |
|---|---|---|
| 13–14 July · RE 26/008230 | Complete principal request to COALZ and entry registration. | Does not establish opening of preliminary/disciplinary proceedings or acceptance. |
| 15–16 July · RE 26/008474 | Additional material supporting identity, corporate capacity and direct interest. | Does not itself establish formal standing or access. |
| 15–16 July · RE 26/008476 | Supervening-event update and confirmation of transfer to the Board, like earlier material. | Internal transfer is not a merits decision. |
| 22 July · COAGC | Art. 44.3: primary competence in Lanzarote; “data do not coincide”; membership-data custody; reported absence of Sun Park/MYND material; no auxiliary file. | Does not prove falsehood, lack of membership or absence of autonomous acts. |
| 20 August · COALZ | Supplemental email in the existing thread, with two visual annexes, audiovisual source and DP 1901 order. | Sending does not establish substantive receipt, preservation or investigation. |
| 20 August · COAGC | Separate communication, then redistributed through the four functional channels used on 13 July. | Broad distribution does not alter territorial competence or prove an institutional response. |
Required outcome, not predetermined outcome. Preservation, preliminary verification, record correction, coordination, a precise request for more material or an express reasoned decision are requested. No sanction is demanded and silence is not treated as admission.
7. Native technical evidence requiring preservation
- Commission, client identity, minutes, powers, certificates and authority documents.
- Plans, reports, measurements, budgets, certificates, photographs, videos and surveys.
- CAD, BIM, Revit, IFC, DWG, DXF, PDFs, hashes, electronic signatures and certificates.
- Creation/modification dates, authors, users, paths, versions, change history and access/transmission logs.
- Rectifications, complementary projects, direction changes and later use before authorities, investors, financiers, operators or courts.
- Membership/habilitation checks and reconciliation of numbers 21428 and 2315.
Native files may determine timing, authorship, scope, included units, instructions, client identity, authority relied upon and correspondence between documentation and works.
8. DP 1901/2026 and Article 262 LECrim
The 12 July 2026 order, NIG 3501643220260016977, records the existence of DP 1901/2026 and referral to the Public Prosecutor for a report on admission in connection with preprocedural inquiry 2/26. It does not establish final admission, an offence or liability.
The communications ask the Colleges for an express assessment of whether information verified through their functions reaches the threshold under Article 262 LECrim. They do not state that the provision has been breached or that receipt of a complaint automatically activates the duty.
9. Finite questions
- Who was the effective client and who signed or supplied the commission?
- What authority and representation were shown, and how were they checked?
- Which units, blocks, common elements and exterior areas were included?
- When did visits, measurements, plans, budgets and renders begin?
- What technical material already existed before 30 November 2021?
- Which versions went to Yaiza and which explain the works observed?
- What material was later used in tourism, investment, finance, RIC/REF, incentives, ERDF, tax or operation?
- What do 21428 and 2315 mean and what was the correct habilitation on 25 February 2022?
- What has each College preserved, which body decides and what review route exists?
10. Related records and right of reply
Acosta Matos perimeterCommunityCabildo / TourismMultiple financial livesPwCGrant ThorntonRSMSan Telmo / RICPE
Correction and response. JDAM, COALZ, COAGC and every materially affected person or entity may submit correction, context and documents. Verifiable corrections will receive equivalent prominence. Non-response will be recorded only as non-response, not admission.
Last reviewed: 20 August 2026. This is an investigative reconstruction, not an official determination.
Sun Park / MYND Yaiza — site and canonical record
Hotel / physical site: Sun Park · MYND Yaiza — PD-SP-O-0042.
Calle Janubio 3, Playa Blanca, Lanzarote 35580, Spain. This identifies the establishment and site, not a corporate owner or determination of title. Canonical address and source variants · Actors, proceedings and evidence.
MASTER MYND · photographs, attributed accounts and chronology