Cross Qual on owner occupied and Dodd Frank

[Clint Worland]

Good morning. I have a deal that came across my desk and I am having a hard time waking away from. Here is the situation:

Borrower Looking for $100k for business purposes in San Diego Ca.

I would have a 3rd position lien on his investment home at 85% LTV worth 1.2m currently.

This same home in 2008 was only worth $800k which would mean my lien would be worthless.

Borrower has agreed to let me cross collateralize against his owner occ( would be 2nd lien position at 85% cltv and business and personal. 

Borrower is a dentist with over $100k per month average deposits over last 24 months .

Borrower states that he needs the cash because he just bought another dental practice. (checked yelp reviews and seems solid)

If I am ONLY in 3rd position on investment home , then this deal is too risky for me. However if there is a way for me to Cross (dodd frank?) and get a PG / business then the deal seems much more ideal. Borrer has agreed to a 12 month bridge loan at 15% with 5 points up front.

The return is sexy however I just don't know enough about Dodd Frank and 12 month bridge loans. I was told by someone else that a short term bridge loan does not fall under Dodd Frank even if its on his Owner occupied?

Does anyone know the answer or know who I can call to get the answer?