Can Portfolio Lenders Refi <12 Months at 85%LTV like Reg. Banks?

[Sam Valme]

I think I did a pretty good job fitting the whole question in the subject! :D 

I've heard of folks leveraging Portfolio lenders to avoid the 4 limited from Freddie and Fanny. I've talked to M&T Bank and they said that even if you pay cash. You still have to wait 12 months to refinance at the ARV. Is this rule the same for portfolio lenders? I'm assuming not sense they maintain control of the loan.