Current status of the draft for a reglamento of the company Reljuv S.A.

12.4.2025

In an initial letter to Reljuv S.A., the latter is requested to ensure the necessary transparency and clarity with regard to the current and planned reglamento for Barrio Cerrado and thus to demonstrate the professionalism and trustworthiness appropriate to such a project. 

Dear Sir or Madam
Today we would like to make public what we consider to be an essential omission on the part of the Reljuv administration and ask for immediate clarification.
In the private purchase contracts, verbal conversations and written inquiries, the buyers were promised a public deed of transfer of ownership for the PROPERTY: Text excerpt from a notarized purchase agreement from 2022:
“... The Promising Seller will transfer title to the PROPERTY to the Promising Buyer once the division in the Parcelization Plan has been made. The promising seller undertakes to sign the public deed of transfer of ownership, without any encumbrance in favor of the promising buyer, once the subdivision procedures have been completed, which will be carried out by the public notary appointed by the selling RELJUV S. A...”
The wording clearly gives the buyers the impression that they will receive a title exclusively for their purchased property as soon as the division procedure is completed.
However, in mid-2023, unbeknownst to the landowners, the Barrio Cerrado Paraiso Verde was registered as a project in the Catastro.
It was not clear to the buyers from the purchase contract that... 
...the creation of a Barrio Cerrado was planned and 
...this foundation would have fundamental effects on the type of land titles

A horizontal land title usual in this construction is subject to drastic restrictions, rules and liabilities, as the buyers have acquired co-ownership shares in addition to their land. 
Thus, changes to the contract were made afterwards, which were decided unilaterally and contained serious new regulations. 
One of the conditions of “horizontal titles” is that the parties agree a regulation on the co-ownership and its management, through a public or private deed (reglamento or barrio contract), which is registered in the national land register in the corresponding section. To date, the agreement of this regulation has been withheld from property buyers. 
According to Paraguayan law, a reglamento must already exist when a barrio cerrado is submitted to the Catastro, which regulates the rights and obligations of the owners in a barrio cerrado, including with regard to their co-ownership of the communal facilities. The version currently available in the Catastro was submitted in summer 2023 and updated in January 24.
The buyers were neither informed nor involved in the process, nor was their consent obtained. 

For examination by our association members, we immediately request 

The submission of the Reglamento (1/2024) in German and English, prepared as a legally binding basis for the further process by a translator authorized in Paraguay.
Answers to the questions: 
What are the conditions and technical requirements for the implementation of a BC according to Paraguayan law? (access, fencing, utilities, percentage of common areas, etc.)?
Does the planned Barrio Cerrado PV meet these requirements?

The time for providing the Reglamento (1/2024) in German and English and the answers to the questions must in any case be before the convening of the first general assembly of the community of owners, and the declaration of division must also be available, as without this information no solid basis can be created - and no legally binding votes can be taken.
The legal entity of the Barrio Cerrado PV is only created by this first general assembly.

The Comunidad Creativa is a community of people living in El Paraiso Verde who want to combine their efforts to deal professionally with the challenges facing the project and the future community of owners.
This letter has been written by this community of currently around 50 investors and should therefore be taken with the appropriate seriousness. 

With joint greetings
Comunidad Creativa Asociacion