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09-07-2018, 03:03 PM #1
Karen, what did I say that was negative? I just pointed out that you keep saying the same thing over and over, which if you go through this thread you have. Not negative true. And you can call me anything you want because I truly dont care.
Kevin I completely agree with your statement. Getting in front of this adapting and changing is the key to survival and ultimately being successfulJohn Celifarco
Managing Partner
Horizon Funding Group
3423 Ave S
Brooklyn, NY 11234
T: (347) 773-3990 | F: (718) 795-1990
Linkedin: Profile
Email: john@horizonfundinggroup.com
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09-07-2018, 03:06 PM #2Karen37aGuest
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09-10-2018, 08:46 AM #3Karen37aGuest
On another bad note did anyone else hear that they are trying to make sure the Brokers /Isos are liquid 100k? Who were domiciled in Calif?
Like a net cap requirement to hold the licence and a bond?
Here is Finras Net Cap Requirement
https://www.finra.org/sites/default/...pretations.pdf
***regulated Finra investments and Regulated loans were my specialities and backyard
When was saying ...i was an osj, series 24...compliance etc ...that = regulation cop over the organizations....which is not my favourite position to be in
Called Super OSJ...like Super Isos Compliance or MasterGeneral Agent...compliance over thr general agents offices and their agents
Article on the benefits of transitioning to a Super Osj
https://www.practicebuildertools.com...mall-bd-to-osj
There is so much to know in regards to regulation of loans and investments...smh
# 1 thing. Someone who was in a compliance position for over 25 years in multiple states with multiple brokers with multiple products, without incident has no problem getting thru regulation.Last edited by Karen37a; 09-10-2018 at 09:16 AM.
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09-12-2018, 09:47 AM #4Karen37aGuest
Check the current exception list on the bill I know from the past that several entities aren’t required to be licensed under the CFLL,
A. Exemptions
The California Finance Lenders Law provides that
certain entities, persons, and transactions are exempt from
the general licensing requirements. Exempt categories
include:
1. banks, savings and loan associations, credit
unions, certain SBA-approved lenders, and
pawnbrokers regulated by the laws of any state
or by federal law;
2. licensed check cashers;
3. colleges and universities making student loans;
4. securities broker-dealers licensed under California
law
5. persons or entities who make no more than five
commercial loans in a twelve-month period, and
the loans are “incidental” to the primary business
of the person relying on the exemption;
6. certain public entities (including municipal
corporations and government agencies);
7. agricultural cooperatives;
8. certain credit card issuers;
9. loans made or arranged by California-licensed
real estate brokers and secured by a lien on real
property;
10. cemetery brokers;
11. licensed “residential mortgage lenders;”
12. commercial bridge loans made by a venture capital
company to an operating company;
13. franchise loans made by a franchisor to a franchisee;
14. certain commercial loans and other investments
made by certain tax-exempt organizations.
Hedge funds that make loans as part of their portfolio. are not exempt if it is their "only" business ( similar to glass steangal vs Gramm-Leach-Bliley Act)
CFL license is limited in its capabilities. The CFL license permits the licensee to lend, but only from its own balance sheet; meaning it must be the lender of record on all loans it originates and funds. In addition, it is limited in its ability to sell loans. Currently, CFL licensees are only allowed to sell loans to “institutional investors” or other CFL licensees. However, this doesn’t mean there aren’t creative solutions to these restrictions. ( with additional requirements and licencing and experience needed...when i get it il print my name in big bold print ..Elizabeth )
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*Some of us are on the move to get the "extended" more advanced Licence( its "above" cfl and harder to get)...pushed me out of my comfort zone again and right back into Venture capital and Bridge Capital ( I just wanted to sit in the corner and call clients and get documents in and fund deals and go home- i hate paperwork)
Check the updated regulations and check with a lawyer...there are fines of $2500 each and jail time that can be incurred with each violation
And I am still staying with my favourite funders
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ADD
___Even though lead generators are not traditionally considered "brokers," these businesses may perform some of the activities for which a CFL license is required. Further, a CFL licensee cannot compensate an unlicensed third party for accepting applications or soliciting loans. Thus, a lead generator may need to be licensed to get paid for leads of California residents provided to a license
***That's the referral business that I have talked about going out the window, and this is the nuclear bomb I have spoken of ***
When you are regulated you cant even take a gift card for more than $100...I am sure some have heard me say by accident ...no gift cards over $99 by accident on the phone..I am on autopilot
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How Dare someone attacks my credibility when I was 100% right. And say I do not want regulation becacause of a background check ..Unlike some, I have a long successful career in Regulated industries ...not one MARK. My friends in real life said. why do you bother talking to people you wouldn't even say hi to in real life.
Regulation is a nightmare. Gl with it. I know my way around the industries that are regulated 30 years is a long long long long time.
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Add. West Coast I said Glass Steagall and Graham leach biley act...do I have to say Dodd-Frank and Volcker rule for you to engage?
You and I can go to the capital hill ...some who don't understand finance will be there, and you and I can slug it out...you can quote Von Mises Adam Smith and Keynesian economics...then tell me to behave and I can respond " whatcha talking bout Willis" Someone else can have picket sign "Karen had a dui" as the paparazzi photos go off saying Karen = Elizabeth lol
( not fighting with you west i need another vacation..see you in a week)Last edited by Karen37a; 09-12-2018 at 11:45 AM. Reason: typo trigger queen
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