I am a lender. My attorney has advised me I do not need a license as long as I stick to these constraints:
There is no problem making loans to investors.
If I make a loan to a homeowner, I need to use a licensed RMLO and do not give any cash back the homeowner.
I do not service loans originated by others, I only service loans I originated.
I hope this helps,
Neil Aggarwal
Property Financing, LLC