Have small park in NY . Tenants own their homes. One of the tenants approached me about the buying park. She doesn't have a down payment large enough for a commercial loan from the bank and the bank won't do it as a residential mortgage. Since she has a home in this park, as her principal residence, I wonder under Dodd-Frank, if I can make a mortgage without a licensed mortgage originator. Has any one done this? Of so any pitfalls?