There is an exemption to these rules for participant loans, given certain requirements are met.

Purchase a multi-family in an appreciating neighborhood, put some sweat equity in the property refi and repeat BRRRR (overtime).However I am not sure if a cash - out refi on a BRRRR would void the tax exemption, but I'm sure your accountant does.

What would become an issue as relates to flipping with an IRA is the tax-exempt entity is engaging in a trade or business activity (as opposed to passive investments such as hard money lending, dividends, rents from real property, etc).  

I live in California and here the law limits non-exempt private lending to 10% annual interest.

According to the American Land Title Association, the following types of loans do not have to comply with TRID:Home-equity lines of credit Reverse mortgages Mortgages secured by a mobile home or dwelling not attached to land No-interest second mortgage made for down payment assistance, energy efficiency or foreclosure avoidance Loans made by a creditor who makes five or fewer mortgages in a year And, in addition, 100% cash transactions (no lender involved) are also exempt.

Necessity of license; use of title; exemptions.

I would like to add if you OF a property to an entity such as an LLC or S Corp and they sign a statement the transaction is for business purposes only (you can do the same thing lending money) that the transaction is exempt from DF.

The feds recognize the underlying IRA owners as exempt, but several states would tax the partnership income.  

Also, perhaps the house wasn't "hidden" from the probate court,may it seems the house was the deceased's homestead, which would make it exempt from creditor claims, i.e.

I am assuming because of an owner homestead exemption and senior exemption both of which I don't totally understand yet.