Personal residence as collateral for business loan

[Robert Weaver]

I am a partner in a hard money lending business, but sometimes a deal comes along that we are not interested in doing for whatever reason.  Occasionally I will do a deal myself.  In this case, I have a borrower who needs money for one of his many entrepreneurial pursuits.  He has offered to collateralize with a stock pledge across multiple of his companies and his primary residence.  I want to cross collateralize against both, but I am being told that I have to be a licensed mortgage broker to take the primary residence as collateral due to Dodd Frank.  I thought I was ok since the loan was not for consumer purposes.  Who is right?