AS of now which is mid June the requirements for getting the Permanent visa are pretty firm. You cannot file prior to completing the full 21 months. You can file during the final 90 days of your visa up to and including 30 days prior to the expiration. WE do not recommend waiting that long but in one case the person was not able to register for the Antecedentes Penales Report which is Mandatory until the final month and the application was submitted and the visa was issued. In addition the Ministerio is not requiring FBI or State criminal reports if you are applying for the same type visa that you had as your temporary visa.
If things change before we are able to update this information we apologize. Please contact us at email@example.com and we will give you the most current updates we have.
As for the Special Exception Investment Visa which allows you to be gone longer than the 90 days per year, it appears there is much confusion and the last information we received was that visa is on hold and will most likely not be offered.
The Ministerio is moving its Immigration offices back to Cuenca but there is no firm date. We have been told anytime between the next month up until January 2020. There is no firm location as yet either.