On Monday 13 Holdings Ltd. missed an opening deadline for the world’s most lavish hotel according to multiple media reports. Opening by July 31, 2017, was one condition of a loan the company, headed by Stephen Hung, the former co-head of Asia investment banking at Merrill Lynch, has with China’s first nationwide state-owned joint-stock commercial bank; Bank of Communications Co.

The loan of HK$3 billion ($384 million) is also about the same amount 13 Holdings still needs to raise in order to finish the $1.6 billion project in Coloane, off the end of the Cotai Strip in Macau. The additional $400m would finish construction of the hotel and pay financing fees and associated costs, according to a Bloomberg report.

While most reports refer to the project as a casino, the company has not used that word for quite some time and Macau gaming regulators have not acknowledged receipt of a request for a casino license. Hung is listed by major financial sources as the Chairman of The Taipan Investment Group and the Vice Chairman of Rio Entertainment Group, operators of Macau’s Rio Hotel & Casino through its affiliates. The Rio license is owned by Galaxy Casino, S.A., the world’s third largest gaming company by revenues, behind only Las Vegas Sands and MGM.

13 Holdings Ltd’s stock prices have taken a hit, having peaked on January 25, 2013, when the company was known as Louis XIII Holdings Ltd. An earlier spike in company share price is not attributable to the hotel project as it occurred several years before Hung announced the luxury hotel.

Bloomberg reports that some early investors have bailed out. Most of the company’s assets are pledged according to the most recent financial statement filed with the Hong Kong Stock Exchange.

13 Holdings are in the final stages of completing the hotel and the company is still seeking operating licenses. They are still not commenting on whether the hotel will open a casino. While a career website still lists openings for a count room supervisor, manager, and cashier, the listings are not hosted on the13.com website but can be reached from there.

While the future of VIP gaming in Macau is an unknown, the volatile sector has shown improvement with the government reporting a 29% year on year gain for July to MOP23 billion (US$2.86b) in gross gaming revenue. Most analysts attribute the growth to VIP gaming, but caution that it is too soon to know for certain if the year-old Macau recovery is stable yet.

Macau Business Daily reported on July 28 that the Macau Government Tourism Office (MGTO) was still waiting for a request to inspect the property, a move needed to get the hotel’s licensing process moving forward. “All documents are already approved but we’re still awaiting the request to inspect the property. Without the request we [can’t] initiate the process to grant a license,” MGTO Director Maria Helena de Senna Fernandes told Business Daily.

A license for any casino would need to come from the Gaming Inspection and Coordination Bureau, and would likely be a sub-license issued by one of the existing concessionaires. Sociedae de Jogos de Macau (SJM), Galaxy Entertainment Group, and Wynn Resorts hold the only true concessions while MGM Resorts, Las Vegas Sands, and Melco Crown Entertainment technically operate under one of the big three. Macau’s current casino gaming concessions are set to expire in 2020 and 2022.

The tender process for new concessions has not been made clear by the Macau government.

With or without a casino, THE 13 is slated to be the world’s most luxurious hotel and the fleet of 30 custom Rolls Royce Phantoms could easily ferry big spenders to tables at remote casinos if needed.

The least expensive rooms at THE 13 should set you back about $1,500 per night, while the most opulent accommodations could run as high as $100,000.

The property will feature 200 villas (suites). La Villa du Compte will have private elevator lobbies, butlers trained by MCM Palace Consultants and certified by the English Guild of Butlers, floor to ceiling baroque details with period and modern artworks, Roman Baths for 6-8 guests, stained glass and marble bathrooms, elaborately carved and gilded baroque headboard beds with velvet canopies, faceted chrome furniture designed by Mr Hung and other leading artisans, and of course, transportation in one the THE 13’s bespoke red Phantom Rolls Royces.