A question for those of you who are using the CASH program or are in markets where there may be local banks who finance homes. Assuming you are NOT doing the Rent Credit program and instead are actually selling homes (ie CASH), are any of you concerned that if you are selling homes in your parks and essentially “steering” tenants into various loan products, that you are acting as a mortgage broker even though you may not be licensed to broker mortgages? Does anyone know the federal laws pertaining to this, or is entirely on a state by state basis.
Note I am not asking about selling homes and carrying paper - I know that has already been banned or at least heavily regulated under the SAFE act. I am specifically referring to the act of selling homes and directing the buyer into various approved loan programs.
Feedback from anyone who has investigated the legal ramifications of this - Frank? - would certainly be appreciated…