Limit on Conventional Cash Out Mortgage

[Larry Fried]

As an investor, my business partner wants to buy a home all cash, have it rehabbed, and rent,  then finance out.  We know about Delayed Financing and is the option he may take, but it is fairly costly. So he is considering other options.  Can he season for 6 months, then do a conventional cash out loan if it will be his sixth mortgage?  Or is there a limit at number 4, or any other number less than 10 (when conventional loans end)?