Limit of 4 transactions using a private lender?

[Anthony Bonanno]

I just met with my attorney regarding my strategy moving forward with flips. I have private lending money available to help fund the acquisition and rehab costs. He said that my private lender can only do a total of 4 transactions, anything over that would fall into some type of mortgage lending/brokerage scenario. I've seen posts regarding a maximum of 4 for conventional lending....but private? Maybe the difference could be buy and hold vs. buy and flip? Is this right?