RMLO needed for land contract sale? 10+ sales this year

[Brian Kempler]

Hello, if I plan to sell 10+ houses this year on a land contract, does Dodd Frank apply to me? Does the land contract sale also require an RMLO to "originate" the financing? No lien will be secured against the house by me (the seller). If it matters, we focus on Alabama (Also Missouri although less activity up there).

[Chris Seveney]

Quote from @Brian Kempler:

Hello, if I plan to sell 10+ houses this year on a land contract, does Dodd Frank apply to me? Does the land contract sale also require an RMLO to "originate" the financing? No lien will be secured against the house by me (the seller). If it matters, we focus on Alabama (Also Missouri although less activity up there).

 Forget what you are giving them, a mortgage, a deed of trust, a land contract... You are entering into a consumer agreement which follows the laws of consumer protection. It is wise to have a RMLO to confirm the borrowers ability to repay and other consumer protection laws. Since this would be considered your course of business because it is not a one off, you should also look into things like using 3rd party servicers etc. to maintain compliance.

If you want to do it right, then yes use underwriters to review the loans and treat it as if you were Wells Fargo originating a loan to yourself. This also includes running credit, getting an appraisal etc.