Owner financing to an investor do I need RMLO?

[Jay Schwichtenberg]

We owner finance around 12 properties a year and usually use an RMLO for these sales since we are selling to an owner occupant buyer.  Recently I had an investor who is interested in owner financing from us for investment purposes. He already owns his home and has two other rentals that he bought with owner financing. He buys properties in his personal name for investment purpose. My RMLO is saying I still need to go through the same process with him. I thought Dodd Frank/Safe Act was to protect owner occupant buyers and that it would not apply to investors since they should be deeded savvy. Is my analysis correct? Thanks.

Jay