Buying Notes - Do I need a MLO license?

[Joseph Wise]

I have an interest in purchasing and creating real estate notes as an investment company in the states listed below. 

I have heard about needing a MLO if I am creating notes but I am confused by the requirements.  It looks like it is state and even locally (city/County) specific. 

The business plan is to syndicate under Reg. D 506(b) to purchase real estate notes with investors.  We would be buying existing (performing and non-performing notes as well as creating notes using private financing.  In this scenario, is it necessary, to get a MLO license? and is there a multi-state licensing or reciprocity?  Are there any work arounds?  Is using a loan servicer sufficient?    Any advice is helpful thanks!

Looking to these States:

- Indiana, Colorado, Georgia, Kentucky, Louisiana, Arkansas, Alabama, West Virginia, Arizona, Florida

[Logan Hassinger]

@Joseph Wise

Check out this link as each state is specific as you are probably aware. For example in OH, you will have to of had your MLO license for at least 3 years before you can own or originate. However in GA, you only need a lenders license (you will also need to have the entity that is holding GA notes to be registered with RA and surety bond like many other states)
https://nationwidelicensingsys...

As for your business plan, I’m not sure how much experience you have in notes, but jumping straight in to operating a fund for your first go around, you’re likely going to find that to be quit challenging. I have no idea as to your professional experience but sourcing notes along with asset management with little to no experience in the industry will prove difficult. (My apologies if my assumptions about your experience in notes is way off base)

I would recommend starting out with a few of your own notes in the states you would like to operate in and build from there.