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Public-record brief

Rancho Estrellita Mitigation Bank: what the public record shows

Built 2026-10-27 from public sources only. Educational, not legal, tax or investment advice. Note numbers link to the list at the end, which links to each source.

1. What this brief is

A summary of what public records say about the proposed Rancho Estrellita Mitigation Bank, the rules that will govern it, and what is still unknown. It is built only from public sources and is meant for learning.

Not investment advice. Rancho Estrellita LLC has filed a Form D notice of a private offering under Rule 506(b).[1] This brief does not evaluate, recommend or solicit any security. A Form D is a notice; the SEC does not review or approve it.[1]

2. Status at a glance

Rancho Estrellita, public record as of 2026-10-27
ItemWhat the record saysEvidence
StageProspectus submitted to the Corps and the IRT; Corps public notice SPN-2024-00321 posted 8 Sep 2026.[2]Public record
Sponsor named in noticeDieguito Asset Management, Inc.[2]Public record
LocationSouth of River Grove Drive, off Highway 46 East, Paso Robles, San Luis Obispo County; notice point 35.629376, -120.494739.[3]Public record
Parcel at the notice pointAPN 019-161-010, about 652.9 acres by GIS polygon area; not legal acreage and not necessarily the bank boundary.[4]Public record (GIS)
WatershedHUC8 18060004 (Estrella); HUC12 180600040405 (Pine Creek-Estrella River). A watershed address, not a service area.[5]Public record
Comment periodExpired 10/4/2026.[6] Initial evaluation letter due under the federal rule by 2026-11-03.[7] Issuance not public.Public record plus rule
CDFWNot on CDFW's list of established banks.[8]Public record
Credits available todayNone. No credits can be issued or sold before approval.[9][10]Rule
Form D issuerRancho Estrellita LLC: $4,000,000 offering, $2,580,000 sold, 6 investors, as of the 2025 filing.[11]Public record

3. Not public, so unresolved

4. Secondary reporting (not an agency record)

Bay Nature reported about 1,700 acres, 32 vernal pools and a hope for about 1,700 credits.[17] This is journalism describing hopes. It is not an approved figure and should not be used as a credit count.

5. The approval path

  1. Corps: prospectus, public notice, initial evaluation, draft instrument, final instrument, with the IRT.[18][7][19][20]
  2. CDFW (for state species or habitat credits): prospectus (30 days completeness, 90 days acceptability), then a bank agreement package (30 and 90 days, extendable by 60).[21][22] CDFW reports meeting timelines for only part of its reviews.[23]
  3. State gate: no bank is operative and no credits issue until CDFW approves in writing and any easement is recorded.[10]

6. Rules that shape the business

7. Public costs

CDFW review fees, 2026 schedule (adjusted every January 1)
FeeAmount
Prospectus$14,480.75[32]
Bank agreement package$36,201
Implementation (paid as credits release)$86,882.25[33]
Total of the three$137,564

Everything else (land, studies, construction, monitoring, assurances, endowment) is not public for this bank.

8. Market signals

9. Questions to ask

  1. What acreage, credit types and service area does the prospectus propose?[12] Where: Corps San Francisco District 2026 public notice list (PDF and figure attachments).
  2. Has the Corps issued its initial evaluation letter, and what did it say?[7] Where: Ask the sponsor; the letter is not posted publicly.
  3. Has a prospectus been filed with CDFW, and when?[8][10] Where: CDFW Conservation and Mitigation Banking program; annual report.
  4. Which species or habitats would credits cover?[13] Where: Prospectus; ask the sponsor.
  5. How does Rancho Estrellita LLC relate to Dieguito Asset Management, Inc.?[14] Where: Ask the issuer; California Secretary of State business search.
  6. Is the bank listed in RIBITS, and with what status?[15] Where: RIBITS (open in a real browser).
  7. What release schedule and performance standards are proposed?[28][29] Where: Draft instrument; ask the sponsor.
  8. What is the endowment estimate and capitalization rate?[31] Where: Endowment analysis in the package.
  9. Who will hold the conservation easement?[10] Where: Draft easement; ask the sponsor.

Notes and sources

  1. RULE / AGENCY FACT Rancho Estrellita LLC, a California LLC organized in 2025 with an address in Solana Beach, filed a Form D notice of an exempt offering under Rule 506(b), industry group "Other Real Estate", equity securities, first sale 2025-06-16. SEC Form D, Rancho Estrellita LLC (accession 0002074439-25-000001), Form D items 1 to 9 (primary_doc.xml) (opens the source in a new tab). Checked 2026-10-27. https://www.sec.gov/Archives/edgar/data/2074439/000207443925000001/0002074439-25-000001-index.htm
  2. RULE / AGENCY FACT The Corps San Francisco District posted a public notice (SPN-2024-00321) on 8 Sep 2026 stating that Dieguito Asset Management, Inc. submitted a Prospectus to the Corps and other Interagency Review Team members for the establishment of the Rancho Estrellita Mitigation Bank. San Francisco District Public Notices, Year 2026 (entry SPN-2024-00321, Rancho Estrellita Mitigation Bank), Year 2026 list, entry SPN-2024-00321 (opens the source in a new tab). Checked 2026-10-27. https://www.spn.usace.army.mil/Missions/Regulatory/Public-Notices/Year/2026/
  3. RULE / AGENCY FACT The notice places the proposed bank south of River Grove Drive, off Highway 46 East, in the City of Paso Robles, San Luis Obispo County, at latitude 35.629376, longitude -120.494739. San Francisco District Public Notices, Year 2026 (entry SPN-2024-00321, Rancho Estrellita Mitigation Bank), Year 2026 list, entry SPN-2024-00321 (opens the source in a new tab). Checked 2026-10-27. https://www.spn.usace.army.mil/Missions/Regulatory/Public-Notices/Year/2026/
  4. RULE / AGENCY FACT In the county parcel layer, the notice coordinate falls inside APN 019-161-010, whose mapped polygon area is about 28,438,344 square feet (about 652.9 acres). San Luis Obispo County parcels map service (SLO_CO_PARCELS), Point query at 35.629376, -120.494739; field Shape.STArea() (opens the source in a new tab). Checked 2026-10-27. https://gis.slocounty.ca.gov/arcgis/rest/services/Public/SLO_CO_PARCELS/MapServer/0
  5. RULE / AGENCY FACT The notice coordinate lies in USGS HUC8 18060004 (Estrella) and HUC12 180600040405 (Pine Creek-Estrella River). Watershed Boundary Dataset map service (HUC8 and HUC12 layers), WBD layers 4 (HUC8) and 6 (HUC12), point query (opens the source in a new tab). Checked 2026-10-27. https://hydro.nationalmap.gov/arcgis/rest/services/wbd/MapServer
  6. RULE / AGENCY FACT The public comment period on the Rancho Estrellita notice expired on 10/4/2026. San Francisco District Public Notices, Year 2026 (entry SPN-2024-00321, Rancho Estrellita Mitigation Bank), Year 2026 list, entry SPN-2024-00321, "Expiration date" (opens the source in a new tab). Checked 2026-10-27. https://www.spn.usace.army.mil/Missions/Regulatory/Public-Notices/Year/2026/
  7. RULE / AGENCY FACT Within 30 days after the comment period ends, the district engineer must send the sponsor a written initial evaluation of the bank's potential. 33 CFR Part 332, Compensatory Mitigation for Losses of Aquatic Resources (the federal Mitigation Rule), 33 CFR 332.8(d)(5)(i) (opens the source in a new tab). Checked 2026-10-27. https://www.ecfr.gov/current/title-33/chapter-II/part-332#p-332.8(d)(5)
  8. RULE / AGENCY FACT Rancho Estrellita does not appear on CDFW's list of banks established in California. Conservation and Mitigation Banks Established in California by CDFW, Approved banks list, Central Region (opens the source in a new tab). Checked 2026-10-27. https://wildlife.ca.gov/Conservation/Planning/Banking/Approved-Banks
  9. RULE / AGENCY FACT A federal mitigation bank needs an approved instrument, including an approved mitigation plan and real estate and financial assurances, before its credits can be used. 33 CFR Part 332, Compensatory Mitigation for Losses of Aquatic Resources (the federal Mitigation Rule), 33 CFR 332.3(b)(2) (opens the source in a new tab). Checked 2026-10-27. https://www.ecfr.gov/current/title-33/chapter-II/part-332#p-332.3(b)(2)
  10. RULE / AGENCY FACT "Until the department has approved a bank, in writing, and, if applicable, a conservation easement has been recorded on the site, no bank shall be operative, vested, or final, nor bank credits issued." Fish and Game Code section 1799 (no bank operative before CDFW approval), FGC 1799(a) (opens the source in a new tab). Checked 2026-10-27. https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?lawCode=FGC&sectionNum=1799
  11. HISTORICAL BID/TRANSACTION SIGNAL The Form D reports a total offering amount of $4,000,000, $2,580,000 sold, $1,420,000 remaining, a $250,000 minimum investment, 6 investors, and no non-accredited investors. SEC Form D, Rancho Estrellita LLC (accession 0002074439-25-000001), Form D items 11, 13, 14 (opens the source in a new tab). Checked 2026-10-27. https://www.sec.gov/Archives/edgar/data/2074439/000207443925000001/0002074439-25-000001-index.htm
  12. UNVERIFIED / OPEN QUESTION The notice PDF and its figure, which would state the proposed acreage, credit types and service area, could not be retrieved by any automated client during this audit. Public notice PDF SPN-2024-00321_PN_2026.09.04 and "FIGURE FOR PN" (Rancho Estrellita Mitigation Bank), Attachments "SPN-2024-00321_PN_2026.09.04.PDF" and "FIGURE FOR PN.PDF" (opens the source in a new tab). Checked 2026-10-27. https://www.spn.usace.army.mil/Missions/Regulatory/Public-Notices/Year/2026/
  13. UNVERIFIED / OPEN QUESTION Which species or habitats Rancho Estrellita proposes to credit is not stated in any primary source obtained. Public notice PDF SPN-2024-00321_PN_2026.09.04 and "FIGURE FOR PN" (Rancho Estrellita Mitigation Bank), Notice PDF not obtained (opens the source in a new tab). Checked 2026-10-27. https://www.spn.usace.army.mil/Missions/Regulatory/Public-Notices/Year/2026/
  14. UNVERIFIED / OPEN QUESTION The public sources found do not state how Rancho Estrellita LLC (the Form D issuer) relates to Dieguito Asset Management, Inc. (the sponsor named in the Corps notice). San Francisco District Public Notices, Year 2026 (entry SPN-2024-00321, Rancho Estrellita Mitigation Bank), Compare S02 entry with S29 issuer (opens the source in a new tab). Checked 2026-10-27. https://www.spn.usace.army.mil/Missions/Regulatory/Public-Notices/Year/2026/
  15. UNVERIFIED / OPEN QUESTION RIBITS, the Corps bank tracking system, could not be reached from automated clients, so no federal ledger entry for Rancho Estrellita was confirmed. RIBITS, Regulatory In-lieu Fee and Bank Information Tracking System, RIBITS home (opens the source in a new tab). Checked 2026-10-27. https://ribits.ops.usace.army.mil/ords/f?p=107:2
  16. HISTORICAL BID/TRANSACTION SIGNAL CDFW's per-bank tables report acres and credit counts but not credit prices. California Conservation and Mitigation Banking, Report to the Legislature, January 2026 (2025 reporting period), January 2026 report, Appendix B (opens the source in a new tab). Checked 2026-10-27. https://nrm.dfg.ca.gov/FileHandler.ashx?DocumentID=245286&inline#page=26
  17. UNVERIFIED / OPEN QUESTION Bay Nature (secondary source) reported that the Rancho Estrellita project covers about 1,700 acres with 32 vernal pools and that the sponsor hopes for about 1,700 credits. Bay Nature, "Price-Tagging Nature" (Summer 2026), Summer 2026 article (opens the source in a new tab). Checked 2026-10-27. https://baynature.org/magazine/summer2026/price-tagging-nature/
  18. RULE / AGENCY FACT The district engineer must tell the sponsor within 30 days whether a prospectus is complete, and must issue public notice within 30 days of receiving a complete prospectus, normally with a 30-day comment period. 33 CFR Part 332, Compensatory Mitigation for Losses of Aquatic Resources (the federal Mitigation Rule), 33 CFR 332.8(d)(2) and (d)(4) (opens the source in a new tab). Checked 2026-10-27. https://www.ecfr.gov/current/title-33/chapter-II/part-332#p-332.8(d)(4)
  19. RULE / AGENCY FACT After the initial evaluation, a sponsor that proceeds must prepare and submit a draft instrument. 33 CFR Part 332, Compensatory Mitigation for Losses of Aquatic Resources (the federal Mitigation Rule), 33 CFR 332.8(d)(6) (opens the source in a new tab). Checked 2026-10-27. https://www.ecfr.gov/current/title-33/chapter-II/part-332#p-332.8(d)(6)
  20. RULE / AGENCY FACT The district engineer chairs an Interagency Review Team (IRT) that reviews documentation for establishing and managing banks. 33 CFR Part 332, Compensatory Mitigation for Losses of Aquatic Resources (the federal Mitigation Rule), 33 CFR 332.8(b)(1) (opens the source in a new tab). Checked 2026-10-27. https://www.ecfr.gov/current/title-33/chapter-II/part-332#p-332.8(b)(1)
  21. RULE / AGENCY FACT CDFW must decide whether a prospectus is complete within 30 calendar days and whether it is acceptable within 90 calendar days after that. Fish and Game Code section 1798 (prospectus review and fees), FGC 1798(c), (d) (opens the source in a new tab). Checked 2026-10-27. https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?lawCode=FGC&sectionNum=1798
  22. RULE / AGENCY FACT CDFW has 30 days to decide completeness and 90 days to decide acceptability of a bank agreement package, extendable by 60 days. Fish and Game Code section 1798.5 (bank agreement package), FGC 1798.5(c), (g) (opens the source in a new tab). Checked 2026-10-27. https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?lawCode=FGC&sectionNum=1798.5
  23. HISTORICAL BID/TRANSACTION SIGNAL CDFW reported that 40 percent of its bank document reviews in the 2025 reporting period were completed on time. California Conservation and Mitigation Banking, Report to the Legislature, January 2026 (2025 reporting period), January 2026 report, p. 2 (opens the source in a new tab). Checked 2026-10-27. https://nrm.dfg.ca.gov/FileHandler.ashx?DocumentID=245286&inline#page=2
  24. RULE / AGENCY FACT "Under no circumstances may the same credits be used to provide mitigation for more than one permitted activity." 33 CFR Part 332, Compensatory Mitigation for Losses of Aquatic Resources (the federal Mitigation Rule), 33 CFR 332.3(j)(1)(ii) (opens the source in a new tab). Checked 2026-10-27. https://www.ecfr.gov/current/title-33/chapter-II/part-332#p-332.3(j)(1)(ii)
  25. RULE / AGENCY FACT In the BEI/CBEI template, credit types include Waters of the U.S., Waters of the State, Covered Species, Covered Habitat and LSA Resources. Conservation and Mitigation Banking Guidelines (2026), 2026 Guidelines, section 3.4, p. 24 (opens the source in a new tab). Checked 2026-10-27. https://nrm.dfg.ca.gov/FileHandler.ashx?DocumentID=79095&inline#page=24
  26. RULE / AGENCY FACT The service area is the watershed, ecoregion, physiographic province or other area within which a bank is authorized to provide mitigation, and must be sized so the resources compensate across the whole area. 33 CFR Part 332, Compensatory Mitigation for Losses of Aquatic Resources (the federal Mitigation Rule), 33 CFR 332.8(d)(6)(ii)(A) (opens the source in a new tab). Checked 2026-10-27. https://www.ecfr.gov/current/title-33/chapter-II/part-332#p-332.8(d)(6)(ii)(A)
  27. RULE / AGENCY FACT CDFW may approve a transfer for a project outside a bank's service area, and may deny one inside it. Conservation and Mitigation Banking Guidelines (2026), 2026 Guidelines, section 6.1.3, p. 63 (opens the source in a new tab). Checked 2026-10-27. https://nrm.dfg.ca.gov/FileHandler.ashx?DocumentID=79095&inline#page=63
  28. RULE / AGENCY FACT Credit releases are tied to milestones and must be approved by the district engineer in consultation with the IRT, who may reduce credits or suspend sales. 33 CFR Part 332, Compensatory Mitigation for Losses of Aquatic Resources (the federal Mitigation Rule), 33 CFR 332.8(o)(8) (opens the source in a new tab). Checked 2026-10-27. https://www.ecfr.gov/current/title-33/chapter-II/part-332#p-332.8(o)(8)
  29. RULE / AGENCY FACT CDFW says credits are typically released in five or six stages, each tied to criteria such as bank establishment, endowment funding or performance standards. Conservation and Mitigation Banking Guidelines (2026), 2026 Guidelines, section 6.1.1, p. 62 (opens the source in a new tab). Checked 2026-10-27. https://nrm.dfg.ca.gov/FileHandler.ashx?DocumentID=79095&inline#page=62
  30. RULE / AGENCY FACT California law requires an endowment for mitigation land to include principal reasonably anticipated to cover annual stewardship costs in perpetuity. Government Code section 65966 (mitigation land: easements and endowments), Gov. Code 65966(b)(2) (opens the source in a new tab). Checked 2026-10-27. https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?lawCode=GOV&sectionNum=65966
  31. RULE / AGENCY FACT CDFW requires a fully funded endowment held by a third party; the endowment analysis must show the projected annual capitalization rate, every task and cost, and administration and contingency. Conservation and Mitigation Banking Guidelines (2026), 2026 Guidelines, section 7.3, p. 69 (opens the source in a new tab). Checked 2026-10-27. https://nrm.dfg.ca.gov/FileHandler.ashx?DocumentID=79095&inline#page=69
  32. CURRENT PUBLIC FEE CDFW 2026 fees: Prospectus $14,480.75 ($12,308.50 if a draft was evaluated); Draft Prospectus $2,172.25; Bank Agreement Package $36,201; Implementation $86,882.25. Conservation and Mitigation Banking Review Fees, Review Fees page, 2026 column (opens the source in a new tab). Checked 2026-10-27. https://wildlife.ca.gov/Conservation/Planning/Banking/Review-Fees
  33. RULE / AGENCY FACT CDFW's implementation fee is collected in proportion to the share of total credits released, and CDFW may stop sales or releases until it is paid. Fish and Game Code section 1799 (no bank operative before CDFW approval), FGC 1799(e)(2) (opens the source in a new tab). Checked 2026-10-27. https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?lawCode=FGC&sectionNum=1799
  34. HISTORICAL BID/TRANSACTION SIGNAL For the 2025 reporting period (Oct 1, 2024 to Sep 30, 2025), CDFW reported 102 established banks covering about 76,913 acres and 66 actively proposed banks. California Conservation and Mitigation Banking, Report to the Legislature, January 2026 (2025 reporting period), January 2026 report, p. 2 (opens the source in a new tab). Checked 2026-10-27. https://nrm.dfg.ca.gov/FileHandler.ashx?DocumentID=245286&inline#page=2
  35. HISTORICAL BID/TRANSACTION SIGNAL For the 2023 reporting period CDFW reported Palo Prieto at 5,086 acres, 5,086 potential credits, 4,170.53 sold and a 915.47 balance. California Conservation and Mitigation Banking, Report to the Legislature, January 2024 (2023 reporting period), January 2024 report, Appendix B, p. 23 (opens the source in a new tab). Checked 2026-10-27. https://nrm.dfg.ca.gov/FileHandler.ashx?DocumentID=227500#page=23
  36. HISTORICAL BID/TRANSACTION SIGNAL For the 2025 reporting period CDFW reported Palo Prieto at 5,086 acres, 4,933 potential credits, 4,725.5 credits sold and a 207.56 credit balance. California Conservation and Mitigation Banking, Report to the Legislature, January 2026 (2025 reporting period), January 2026 report, Appendix B, p. 26 (opens the source in a new tab). Checked 2026-10-27. https://nrm.dfg.ca.gov/FileHandler.ashx?DocumentID=245286&inline#page=26