OPEN FILE · DOCUMENTS BEFORE CONCLUSIONS
This gateway does not ask CNMV to adopt Project Sun Rock’s global theory or determine civil title, insolvency, grant compliance or criminal responsibility. It provides a bounded review of information, governance, conflicts, due diligence, re-entry, funding, preservation and any correction within the RICPE perimeter.
This note updates the reading without deleting the dated text and historical states retained below. Earlier wording about a future transmission of the 17 August report no longer describes the complete history reviewed. This release does not publish private originals or email bodies.
CNMV resolution 2026008544 identifies documents absent from the historical supervisory corpus but acknowledges the certificate as Annex 3 to the December 2025 request: it does not mean never received. Resolution 2026035232 invokes art. 233 secrecy, not repetitive-request inadmissibility. The 6 May reply acknowledges consideration of the facts in supervision: total inaction is not asserted.
The native cross-border email and receipt REGAGE26e00074329732 have been recovered: presentation on 20 August at 15:11:09, destination EA0042970 — CNMV. The 27 August acknowledgement concerns the 20 August transmission. Supplements followed, including three parts with 6, 10 and 2 files and a technical addendum. The formal 17 August RICPE report appears among the transmitted annexes. Neither sending nor the earlier acknowledgement proves incorporation or examination of each later delivery.
Decree 000222/2026 of the Fourth Section of the Audiencia Provincial de Las Palmas terminates RPL 3319/2025 because the appeals are consolidated into RPL 3304/2025. It does not reject removal on the merits. The context of complaints against insolvency administration, judicial conduct and private actors remains, without treating allegations or pending proceedings as adjudicated responsibility.
Resolution 2026149422, incoming 2026114903, extends the access-response period by one month for volume and complexity. It is not a refusal, merits decision or suspension of all separate preservation and supervisory functions. The covering email requests acknowledgement; this publication is not that acknowledgement.
Identity between the 24 August REG-AGE event PD-SP-EVT-0152 and CNMV receipt on 25 August is not assumed. Reconciliation of every later transmission with all its canonical identifiers, and each file with material actually incorporated by CNMV, remains open. This reading projection reuses existing references, creates no parallel register and certifies no universal completeness.
provisional event label withheld · provisional event label withheld · provisional event label withheld · provisional event label withheld
We invite the competent CNMV teams to use this landing page and the linked source record to connect the reported facts to a concrete, proportionate action. We request assessment and lawful action—not acceptance of a predetermined finding of criminality, a blanket seizure or closure of lawful businesses.
The official register lists RIC PRIVATE EQUITY INVESTMENT PARTNERS, S.C.R., S.A., no.295, registered 25 October 2019. Registration does not establish misconduct, a listed-security nexus or the statutory intervention threshold.
CNMV · RIC PRIVATE EQUITY INVESTMENT PARTNERS, S.C.R., S.A. · 295
CNMV stated that the reported facts had been taken into account in its supervisory activity and invoked supervisory secrecy. The question is the scope, adequacy and next legally justified step—not an unsupported assertion that CNMV did nothing.
Existing RICPE source dossierIncoming 2026114903 / outgoing 2026149422: one additional month for the public-information decision because of volume and complexity. It is not a refusal, a merits decision or a decision to suspend all separate supervisory/preservation work.
provisional event label withheld · Separate covering emailAssociate the new material with the existing record; identify the competent functional team and a secure channel for source files. Keep supervisory reporting, investor complaints and SAIP distinct.
Preserve relevant CNMV-held versions and correspondence. Assess targeted requirements for investment approvals, title/conditions, source-and-use, conflicts, Series F/G and subsequent transfers under the applicable information/inspection powers.
Compare available supervisory requirements, intervention or replacement under art.102/arts.72–75, and judicial protection requested under art.86.1(d). Identify the entity, evidence, risk, legal threshold and less disruptive effective alternatives.
Place concrete criminal indications and a specified digital-preservation schedule before the competent prosecution/judicial-police authority. LECrim 588 octies is their power, not CNMV’s. EPPO requires a qualifying EU-financial-interest nexus.
LECrim · arts. 105, 262, 282, 456, 544 quater, 588 octies, 589, 764, 803 ter · Ley 50/1981 · arts. 3–5, 19 · Ley 6/2023 · arts. 233, 243–244 · Regulation (EU) 2017/1939 · arts. 22–25, 31–32, 120
Design any justified measure around employees, guests, lawful suppliers, creditors and good-faith investors. Test liquidity, contracts, grant advances, costs and review rights; do not transfer business control to the complainant.
Código Penal · arts. 31 bis, 33.7(g), 109–129, 408 · Real Decreto 948/2015 · Ley 35/2003 · arts. 70–75 · Ley 38/2003 · arts. 14, 30, 32, 34.4, 35, 37, 44–49
If intervention/replacement is adopted, apply BOE publication and Registro Mercantil registration under art.73.3. Assess protective disclosure within art.243’s actual scope, and communicate the procedural information legally available without exposing reserved investigations.
Ley 35/2003 · arts. 70–75 · Ley 6/2023 · arts. 233, 243–244 · Ley 19/2013 · arts. 12, 14–16, 20, 24
This asks CNMV to assess action ex officio on supported information; it does not assert that Gil satisfies the specific shareholder/entity petition conditions of art.73.1. Any preferred rapid response interval is an operational request, not an invented statutory deadline.
It organises records, status, production, contrary evidence and dependencies. The public site is a map; every material proposition must return to its primary source.
It does not turn an alert into proved fraud, a registration into retrospective validation, a referral into a merits decision or supervisory secrecy into proof of inaction.
PROFESSIONAL READ · 7 MINUTES
The controlled record identifies filing 2021002141 of 13 January 2021 and later supervisory actions acknowledged by CNMV.
Reconstruct what was said about acquisition, title, encumbrances, investment and timetable, who approved it and what reservations existed.
54 CAM units, 190 LPB units and 18 third-party units; CAM acquisition future/conditional; unsigned LOI; full due diligence not started.
CAM filed the certification in Insolvency 36/2012. Purpose, authorisation, receipt and treatment should be identified.
Identify the new evidence, satisfied condition, waiver, valuation and decision that allowed the project to be reactivated.
The formal communication was submitted to RICPE and technically acknowledged by its platform. Admission, investigation, preservation, Board treatment and merits are not established.
CONTROL POINT
Fragmented ownership, future/conditional acquisition, unsigned LOI, full due diligence not started and prior withdrawal/conditionality.
Re-entry, later title within its exact perimeter, HNT, funding, Regional Incentives, ERDF and MYND operation. Each step needs its own record, decision-maker, date and boundary.
Rule: today’s operating hotel and later title do not retrospectively answer what was documented, verified, conditioned or corrected in 2020–2021.
COMPETENCE
DECISION TREE
Identify the policy, admission criterion, DD, valuation, conflict or condition.
Produce the primary record. If not, identify the contemporaneous deficiency.
Authority, reasons, limits, recusals, conditions and monitoring.
No issue, correction, requirement, preservation, referral or reasoned supervisory action.
MINIMUM SUFFICIENT PRODUCTION
Number control: the 20 September 2023 prospectus totals €6,570,713.56; a separate accounts reconstruction gives €6,573,703.10. The €2,989.54 difference remains open and is not normalised.
OPEN KIMONO · INSPIRATION AND WARNING
Opening the file does not mean disclosing supervisory secrets or protected data. It means being able to explain what entered, what was checked, what was missing, what contrary evidence was considered, which unit acted and what real status the matter reached.
Boundary: this list does not assert that CNMV or RICPE engaged in every negative practice. It offers a public, documentary and falsifiable test for the real file.
Series F/G control: Series F/G · suitability → separates the 2022–2023 administrative authorisation, source-specific amounts and use-of-funds questions without treating them as a fraud finding.
DEPENDENCIES
PUBLIC STATUS
The 17 August 2026 communication was submitted to RICPE. The planned later transmission to CNMV will not be described as sent, registered, acknowledged, examined or decided until the primary receipt proves each stage.
Official professional route: CNMV states that professional matters should be directed to the department competent for the subject through the “Any document, application or communication addressed to CNMV” electronic-office procedure. Official CNMV source →
The appended notice block is not included in this public projection because its provisional event and source identifiers have not been reconciled with the canonical institutional register. Twenty event labels and eighteen source labels remain under review; seven event labels collide with existing canonical records. The source is preserved in the private repository. No conclusion is drawn from this temporary withholding.
One connected factual inquiry with distinct criminal, civil, professional-discipline and recovery tests. Includes the 2022 recovery correspondence, 3 September pleading and July provisional dismissal; no assignment, guilt or stay is presumed. Read the sources, countercase and outstanding evidence.
Read the open letter to Portfolio’s board and compliance, the verified director/shareholder and international-nexus review, and the expanded alternative disclosure memorandum. The dated comparison separates existing disclosures, the 2020–2021 title/diligence tension, San Telmo client introductions, attributed criminal allegations, financing and unresolved proof.