Cross Qual on owner occupied and Dodd Frank
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?