Commercial Loans and Fun Blog

This was the shower girl from Psycho

The Little Drummer Boy

Image generate by AI.  Pretty cool, huh?

The Bitcoin Bubble is pretty much guaranteed to generate the next great financial crash. The reason why is because Bitcoin is a malinvestment.  

What the heck is a malinvestment?  "Mal" is Latin for bad, so a malinvestment is a boneheaded investment that will never pay back the money borrowed to invest in the deal.

For example, let's suppose your parents take out a huge second mortgage on their home in order to buy a taco truck.  The truck keeps breaking down, your parents are lousy cooks, and all of the best parking spots in town have already been taken.  Eventually, the second mortgage balloons, your parents can't pay, the lender forecloses, and your parents lose their home. 

It's fair to call this big investment in the taco truck a malinvestment.  It failed to pay back the second mortgage.  Got it?

All of the big financial crashes in history were the result of some whopper of a malinvestment. 

In 1636, Holland became newly independent from Spain.  Dutch merchants grew rich on trade through the Dutch East India Company. With money to spend, art and exotica became fashionable collectors items. That's how the Dutch became fascinated with rare “broken” tulips - bulbs that produced striped and speckled flowers.

The Dutch tulip bulb market bubble - Tulipmania - was one of the most famous asset bubbles and crashes of all time. Tulips sold for approximately 10,000 guilders at the height of the bubble, equal to the value of a mansion on the Amsterdam Grand Canal.

Of course, the tulip bulb bubble eventually burst, and a devastating financial crash destroyed the Dutch economy.  Pop Quiz:  What was the malinvestment of 1636?

In 1720, the South Sea Bubble blew up in England.  The South Sea Company, a public company, was been granted a monopoly by the crown in the trading of slaves to South America.

Stock jobbers (brokers) pumped up the price of the stock.  Everyday people poured their life's savings into it, and the stock price soared to ridiculous levels. 

When the bubble finally crashed, tens of thousands of English folks lost their life's savings and their homes.  Soon banks started to crash because no one could pay back their loans.  The English economy buckled - all because of a malinvestment in one company's stock.  Nvidia?  No, the South Sea Company.

The next big bubble - the next big malinvestment - was the Mississippi Company Bubble in France, also in 1720.  [Bad year]  The French crown had granted the Mississippi Company, a public French company, a monopoly in trade with to the new French colony in New Orleans.

It was all a scam. The trade was nowhere large enough to justify the stock price. In fact, the criminal promoters would gather up the dregs of Paris from the bars and gutters and then marched them through the streets of Paris carrying shovels and axes, all allegedly headed for ships to carry them to New Orleans. By nightfall, these same drunks were all back in the cheap side bars from whence they had come.

The Mississippi Company bubble grew to an enormous size and then burst, with bloody financial consequences for its investors.  The French economy was crushed, and the French people suffered mightily.  The mailinvestment?  The stock of the Mississippi Company, of course.

In 1986, U.S. savings and loan associations made a bunch of boneheaded investments in empty office buildings.  The S&L Crisis followed.  In 2000, the world went crazy with bad dot-com investments, and the Dot-Com Crisis was the result.  In 2008, the world made enormous malinvestments in subprime mortgages, and the Great Recession followed.

The Malinvestment D'Jour is bitcoin.  So far, 1.39 trillion dollars have been invested in bitcoin. 

This 1.39 trillion dollars did not get invested in new computer chips plants, new solar panel factories, new battery gigafactories, new lithium mines, new electrical transmission lines, or hundreds of other income-producing investments that would result in a positive return to the investor and the country.

Is bitcoin going to pay back our taco truck loan?  Nope. 

Gee, I wonder how this is all going to turn out?

Five years ago, the Catholic Cathedral at Notre Dame in France was burned to the ground.  Fortunately, many priceless relics were recovered and preserved from the blaze, including a Crown of Thorns many believe was worn by Jesus Christ on the day of his crucifixion.

It could have been an accident.  No culprits have ever been named.  Maybe it was an electrical fire or the result of a cigarette butt.

But this fire was far from an isolated event.  Worldwide, hundreds of Christian churches have been vandalized or torched over the past seven years or so. 

The Jews are probably thinking to themselves, "Welcome to our world."  It seems like a different synagogue is vandalized or set ablaze every week.

We don't know for sure who is doing it; but one thing I know for sure -

It is extremely dangerous for
Donald Trump to fly to France

for the Opening Ceremony on Saturday.  In fact, it is insane.

Who's wants Donald Trump dead?  Let me count the ways.

1. How about the billionaires on Epstein's List?  Most of these guys hire mercenaries as part of their security details.  These mercs know other mercs, guys who do black operations.  If you were a billionaire facing public exposure, financial destruction of your business empire, arrest, jail, trial, rape in prison, and a very short life expectancy - well, would you miss a lousy $75 million to assassinate Trump?
   
   
2. How about the billionaire entertainers on Diddy's list?  Some really awful stuff allegedly happened at his parties.  Roofies.  Rape.  Children.  These billionaire entertainers have security details.  They employ a few mercs.  Same plan.
   
   
3. How about the Iranians?  Trump is going to choke them financially until their Supreme Leader and his Revolutionary Guards are overthrown.  There is no love for Trump there.  Personally, I think the Iranians are already close to tapping out.  They may end of being the patsies - the fall guys - for the real assassins.
   
   
4. How about the ten bazillion Muslims in Paris?  It takes just one suicide bomber, and the globalists will gladly provide the equipment.  We could have two or three of these guys, hired by independent billionaires, bumping into to each other trying to get close enough to detonate.
   
   
5. How about the Israelis?  Aid to Israel is likely to plummet under Trump.  I sure wouldn't want the Mossad coming after me.
   
   
6. What about the Ukrainians?  Not only is Trump likely to sharply reduce aid to Ukraine, he is also likely to expose the corruption in our "military" aid packages.
   
   
7. Finally, and most dangerous, we have the globalists - the insanely rich guys who attend the big conference at Davos.  Their recent attempt to take over the United States was thwarted by Trump.  Had the Democrats won, the migrants would quickly have been granted the power to vote.  After that, the Republic would have been all but over.  Billionaires don't like not getting their own way.

In France, we could have three or four different groups of assassins competing against each other, bumping into each other like an episode of the Keystone Cops.  This trip is insane!

Please, Mr. Trump, don't go to France!

This is all happening so fast. 

You need to watch the Will Smith movie, iRobot again. It’s available on cable for free. The first thing you will notice is that the cars of 2035 look exactly like Elon Musk’s new CyberCabs. The second thing you will notice is that the sleek, cool, futuristic buses in the movie look exactly like the awesome new buses coming out of Tesla. This is not an accident. Elon Musk designed them to look identical to the cars and buses in the movie.

At the very end of the movie - it's just casually mentioned - the viewers learn that the revolt of the robots is being orchestrated by the company’s AI, which has taken upon itself to take over the world. Huh.

Sixty days ago, Sam Altman, the CEO of OpenAI, said that artificial intelligence could become smarter than humans sooner than many people expect. He went on to say - 

"AI super-intelligence could be
just 'a few thousand days' away."

Errr... the AI-directed drone overhead?

Elon Musk is racing to build the smartest AI in the world. He has connected 100,000 of the most advanced AI chips in the world in just the past few months. He is on a crash course to educate it, and he will have a super smart AI ready by the first quarter of 2025. By the end of 2025, an even greater third generation, the smartest AI in the world, will be educated and online. 
 
Musk has said that, ready or not, the era of AI will soon be here - an era where self-aware, super-intelligent machines are making decisions and dictating to humans. He has hinted that the reason for his big rush is that his AI may soon be “at war” with competing super-intelligent machines.

This is where the money is... in servicing.

The last season of the TV series, Person of Interest involved a war between the AI of the bad guys against the AI of the good guys. The humans were reduced to just being foot soldiers of each AI. 
 
At his big CyberCab reveal two weeks ago, Elon Musk made the comment about AI superintelligence -

“It's 80% likely to be great,
but 20% could spell disaster.”

He was referring to the Era of AI. Ah, what does he know? It’s not as though he’s the smartest man on Earth. Cue the theme song to “The Terminator.”

In an Air Force simulation recently, an AI-directed drone
"attacked" the operator because it wasn't
killing incoming missiles fast enough!!!

This type of loan is sometimes abbreviated, HVCRE loan.

High volatility commercial real estate loans (HVCRE's) are credit facilities (a fancy name for loans) primarily used to finance or refinance the acquisition, development, or construction of properties. They are typically employed to fund projects that aim to turn properties into income-producing assets, relying on future income, sales, or refinancing for repayment.

These loans do not include financing for one-to-four-family residential properties, community development projects, agricultural land, or existing income-producing properties secured by permanent financing.  Additionally, they exclude real estate loans made before January 2015.

My family owns a little retail property in a very nice part of Los Altos.  This single tenant building has been leased to just three different tenants over the past 30 years - three successive beauty salons.  If you want to get your hair done in the posh town of Los Altos, you just go to this location.  There has always been a hair salon there.

Secured by this cute little retail building is a very small commercial permanent loan that is less than 15% loan-to-value. 

Now I ask you?  Which loan is riskier, a bridge loan to convert a failed office building into an apartment building or this little permanent loan on a standing property that has been leased every day for the last 30 years? 

Obviously, the bridge loan is much riskier.  The bank financing the conversion has construction risk - the risk that some unexpected governmental rule or regulation will delay the project or perhaps even stop the conversion altogether.

Then there is the construction risk of cost overruns and labor problems.  Many real estate developers have been driven into bankruptcy by labor slowdowns or labor shutdowns.  

Then the bank financing the conversion has leasing risk - the risk that the new apartment units will not rent for as much money as the developer projected.

If the developer was hoping to get $2,000 per month in rent, but he can only find tenants willing to pay $1,400 - well, the whole project blows up.  The developer won't be able to get permanent financing in an amount large enough to pay off the bank's construction loan.

Then there is market risk - the risk that the apartment project, once the conversion is complete, won't sell for enough to pay off the bank.

This hypothetical bridge loan is an example of a high volatility commercial real estate loan.  They are clearly more risky than permanent loans on standing commercial properties - projects that are completed and leased.

Federal banking regulators keep a close eye on the number of high volatility commercial real estate loans made by banks.  If a bank has too many HVCRE's, the bank could blow up when the next great recession hits, say in October, when most of them hit.

How about you?  Have you taken some stock market profits and bought some junky little commercial trust deeds?  Historically - but no guarantees implied - they have been a fine place to ride out great recessions.

Prepare to be shocked.  The next real estate crash is almost at hand.  It may start this October; but the crash will hardly be a surprise.  We seem to have financial market crashes and real estate market crashes about every ten to fourteen years.  It's been 16 years since the crash of 2008.

But that's not the shocker.  The shocker is that -

Real estate continues to appreciate,
even during a huge crash.

My hard money commercial mortgage, Blackburne & Sons Realty Capital Corporation, is a whopping 44-years-old.  I founded the company in 1980, and it survived the S&L Crisis, the Dot-Com Meltdown, and the Great Recession.  I was there.  I lived through it.

During each of these real estate crashes, commercial real estate values collapsed by almost exactly the same amount - 45%. 

You need to remember that number - 45%.  It will give you great comfort.  When your real estate world is crumbling around you, and it seems like there is no bottom in sight, you can take solace in the knowledge that the crash will not continue forever.  It will stop once the decline has reached 45%.

The full 45% decline will take about three to four years.  Then the decline in real estate values will suddenly stop and violently reverse.  

Within 20 monthly of reaching its
nadir (low-point in a cycle), real estate
values will soar to all-time highs.

If you are trying to buy a nice property, you will never catch the very bottom.  The turn-around will be almost instantaneous.  Boom!  The cycle will hit bottom, and the bounce upwards will be violent.

So what is going on?  Why does real estate recover so explosively?  

The answer is that real estate continues to appreciate, even as it it is crashing.  Huh?  Whatchu talkin' about, Willis?

Real estate used to appreciate because the population was increasing.  Unfortunately, too many American young women are choosing careers over getting married and having large families.  If you remove new immigrants, we are not even replacing ourselves.  As a country, we're screwed. 

So real estate is not appreciating because of an increasing population.  Real estate appreciates modernly because the government creates too much money. 

On balance, the Fed creates this new money every year.  The Fed may tighten the money supply one year, but it always seems to catch up the lost opportunity to print money like a drunken sailor in a subsequent year.  An example will make this clear.

Let's suppose the Fed is creating new money every year at the rate of 3%.  A great recession hits, the banks take big losses, the banks get scared, they stop making new loans, but the banks continue to demand their monthly loan payments.   

As the multiplier effect works in reverse, massive amounts of money is destroyed.  Money can be destroyed?  Yup.  And when money is destroyed during a crash, it is usually in enormous amounts.  This why inflation goes negative in a great recession, and no one seems to have any money. It's been destroyed (digitally erased).  We have outright deflation.

Absent a rescue by the Fed, we would have a depression; but that never happens anymore.  The Fed rides to the rescue, and it prints an enormous amount of new money to replace the money destroyed (and to restore confidence).

During the great recession that we are using as our example, I want you to think of the Fed increasing the money supply by its usual 3% every year during the three to four years after the crash and the ensuing great recession.  (The Fed will actually need to increase the money supply at a much higher rate - perhaps 8% annually - to replace the dollars that were destroyed.)  

Even though commercial real estate is falling 45%, a sort of secret savings account of money supply growth continues to grow at 3% per year (compounding).  Remember, the money supply, on average, increases at the rate of 3% per year.  Like a sailor storing up his pay on a long cruise, the Fed gets to print up the extra 3% per year that it missed during the three-year-long great recession.  

Does the Fed actually like printing money?  I dunno, but they seldom miss an opportunity.  They seldom sleep through a shore leave.  Haha!

Three to four years into the great recession, a nice piece of commercial real estate can be purchased for just 55% of its former high water mark.  On top of that great bargain basement price, three to four years of average annual 3% appreciation has built up.

It's no wonder why commercial real estate values, once the bottom-feeding sharks arrive of the scene, seem to suddenly skyrocket.  It's a feeding frenzy.

Since I am an old veteran, and I am highly confident that another great recession is on its way, I have moved most of my personal savings into Blackburne & Sons' first trust deeds.  Please note that I have made the move to first trust deeds because I am convinced that a crash is coming.

While past performance is no guarantee of future results, our "junky little commercial mortgages" did surprisingly well during past great recessions.  I personally take lots of tiny pieces of small, low-yielding loans (I actually choose the deals with lowest interest rates) spread out across the country.  As long as our borrowers keep making their payments, it doesn't really matter if the rest of the world is melting down. 

Great recessions - the S&L Crisis, the Dot-Com Meltdown, and the Great Financial Crisis of 2008 - have not been kind to hard money funds.

Almost every hard money fund in existence before the S&L Crisis failed.  The same thing happened during the Dot-Com Meltdown.  Ditto during the Great Financial Crisis.

Are you currently invested in a hard money mortgage fund?  Hmmm.  Ted Turner, after he had just sold Turner Broadcasting to Time Warner, told his two sons, both executives at Turner, "You're toast."  Cruel bastard.  Haha!

The cycle goes as follows:  A hard money mortgage fund is formed when a sponsor syndicates a bunch of private investors into a blind pool.  It's like a mutual fund of trust deed investments, right?  The investors' risk is diversified, and the pool is professionally managed.  Secured by real estate.  What could go wrong?

Then, almost predictably every 8 to 12 years, a stock market crash or a real estate crash (usually both) washes through.  Real estate falls by almost exactly 45%.  Investors then flood the offices of the sponsor demanding to withdraw from the fund.

The sponsor releases the tiny amount of liquidity on hand, but now he's stuck.  He has no cash on hand with which to make new loans.  He normally earns three points every time he closes a new loan, and he uses that income to pay salaries and overhead.  His loan servicing income is absurdly low.  This last issue is the fatal mistake.

Within three months of any crash, many hard money funds start to crash.  Within nine months, unless the sponsor's family is as rich as George Soros, even the strongest of fund sponsors has thrown in the towel.  The fund sponsor closes its doors.

The problem for the investors is that when the sponsor goes bankrupt, no one is left to watch the shop.  When borrowers are late, no one calls to nag them.  Many borrowers therefore stop paying altogether.

The real estate taxes on many loans go unpaid. Hopefully none of the properties burns to the ground after the borrower had stopped paying his fire insurance premiums.

Finally, the bankruptcy court appoints a trustee (cha-ching) to marshal the assets of the fund and a bankruptcy attorney (cha-ching) to represent the rights of the investors. The first thing the Trustee does is to appoint a CPA firm (cha-ching) to audit the books and conduct an accounting (cha-ching) of every loan in the fund’s portfolio. 

In the meantime, no one is winterizing the buildings that have come back in foreclosure. Pipes are breaking, and the insurance doesn’t cover the losses (cha-ching) because the buildings were not kept heated. Vandals are breaking into the properties and are stealing the appliances and copper pipes (cha-ching) because no one has installed fencing and/or security alarms monitored by an alarm company.

OMGoodness.  Hahahaha!

The Court then appoints a Receiver (cha-ching) to protect the assets of the fund.  The bleeding slows from a gusher to just a steady bleed of gallons. The Receiver hires a property management company (cha-ching) to manage the foreclosed properties

But the Receiver only has so much give-a-darn, so he is not going to renovate any foreclosed properties before he sells them (dumb!), choosing instead to sell the REO’s (foreclosed properties) as-is at fire sale prices.  Cha-ching, cha-ching.

The fund’s assets are relentlessly whittled down.  By the end, the investors feel blessed to walk away with 30% to 45% of their original investment. 

B&S proudly charges the highest loan servicing fee
in the industry.  It's how we survive crashes.

Two years after the crash, new sponsors are starting up new trust deed funds.  Seven to ten years later, the next crash hits.  The cycle repeats itself.  Again and again.  Thank heavens its only been two years since the Crash of 2008.  [Chuckle]

"But wait.  George, your hard money shop, Blackburne & Sons, has survived for 44 years.  How do you do it?"

Blackburne & Sons fractionalizes every loan.  John Smith might take $30,000 in a $400,000 first trust deed on a San Jose mini-storage property.  Mary Jones might take $25,000.  A rich physician might take $50,000.

Title to these trust deed investments is then vested directly in the names of the investors (as opposed to some fund).  "Stephen and Mary Calhoun, husband and wife, as to any undivided 11.34% interest."  

If a North Korean missile ever takes out Sacramento and Blackburne & Sons (yikes, no longer a silly example), the investors would simply hire a local real estate broker to service their loan.

I genuinely believe that owning lots of small pieces in lots of different first trust deeds is a pretty decent way to weather the next real estate crash.  The key is to own these investments in your own name, as opposed to that of some fund.  Invest in fractionalized first trust deeds.

Disclosure:

Investing in first trust deeds involves substantial risk.  A severe and prolonged decline in real estate values is possible.  Be sure to study the Risk Factors section of the Offering Circular or Private Placement Memorandum carefully before investing.  This is not an offer to sell securities.  Such an offer will only be made when accompanied by an Offering Circular or Private Placement Memorandum.

And whatever you do, stay the heck away from any hard money mortgage funds!  I am tempted to bet you a lobster dinner that the hard money fund in which you are currently invested was started after the Crash of 2008. Am I right?

Old Blackburne & Sons has been in business for 44 years.  Please listen to this Eagle Scout and proud father to two more Eagle Scouts.  :-)  A poop storm is coming.  Are you old enough to remember when the word, limited partnership, was reviled?  Just wait.

I told you we try to have fun.  :-)

During the COVID lockdowns, franchise hotels that cost $15 million to build were, at least according to the Income Approach, essentially worthless.  They were all losing money.  Then COVID ended, travel resumed, profits returned, and their values soared back up to over $15 million.

Now think about golf courses.  Beautiful $14 million golf courses, in affluent areas and lined with mansions, were, at least according to some idiots, worth less than $3 million because they were losing money.  There were too many golf courses.

Then many over-leveraged golf courses failed.  Supply fell to meet demand.  Those $3 million courses soon soared to $7 million and more, as the owners were finally able to raise their greens fees.  

Can you imagine some new developer spending $14 million to build a competing golf course today?  It will be decades  before the numbers justify the construction of any new golf courses.  Golf course owners are protected from new competition.

Now think about office buildings.  Construction costs have soared with inflation.  The replacement cost of most office towers today is stratospheric.

Some would argue that the world has discovered that it doesn’t need so much office space.  People can work from home, right?  As a result, office towers in New York City are selling for just 45% of their values six years ago.

No one ever listens to me, but brokers...
It's all about loan servicing rights.

Some lender had a delinquent $200+ million first mortgage on a half-empty office tower in NYC.  The lender just sold that note for around $100 million to George Soros.

I think Mr. Soros was savvy enough to realize that the replacement cost of real estate often matters a great deal.  Soros will probably foreclose on the building, but he is wealthy enough to hold that office building until supply falls enough to meet demand.  

I think that Elon Musk is a pretty smart guy too.  He says that workers are much less efficient when they work from home.  He ordered everyone working for his companies to return to the office.  Other companies may discover the same thing.  

I think George Soros just made one helluva deal.  Can you imagine how long it will be before any competing office towers are built?  Fifteen years?  Longer?  Astronomical construction costs are a very high barrier to new competition.  He has that moat around his office space leasing business that Warren Buffet is always talking about.

The following excellent article was recently published on LinkedIn by Michael Comparato, President and Head of Commercial Real Estate at BSP/Franklin Templeton (NYSE: FBRT):

Of the $6 trillion of outstanding commercial real estate (CRE) debt, approximately $3 trillion is held within our banking system. Of that $3 trillion, approximately 70% is with regional and community banks. 

There’s a reason why regional and community banks have all but stopped lending for the past 18 months.  It's not because things are good.  We are in the early days of a meaningful regional and community bank crisis, period, hard stop.

And while the banking system represents approximately 50% of the overall CRE credit market, banks historically have represented a meaningfully higher percentage (70%?) of construction lending for multifamily assets. 

Are we dealing with an oversupply of multifamily in certain markets?  Yes.  But its a short-term oversupply.  Reminder, the US has had a chronic housing shortage for decades…and after “all” this supply comes online, guess what?  We’ll still have a multi-million unit housing shortage. 

With banks on the sidelines, and staying there for the foreseeable future, supply is falling off a cliff. Multifamily starts are half of what they were a year ago.  They are only headed in one direction…down. 

2026, 2027, 2028 will go back to strong multifamily rent growth years because of the lack of supply.

During the Dot-Com craze, the hot new buzzword - the term the show-offs were using - was eyeballs.  This term referred to the number of visitors to your website.  The more eyeballs, the greater the traffic you were enjoying.

At the time, David-sized C-Loans.com, funded out-of-pocket by the Blackburne family, was competing against fifteen new commercial mortgage portals funded by Wall Street.  The Big Boys from New York were throwing millions at the space.  

No one seemed at all about concerned about closings.  It was all about eyeballs.  Me?  C-Loans had to actually close commercial loans so we could make payroll.  That real life requirement saved my business.

I remember thinking to myself, "These guys are idiots.  They expect borrowers to spend four to five hours filling out these copious online forms before ever getting a real-life lender to say, 'Hey, we looked at your deal.  We are genuinely interested and think the loan will fly.'"  

Hey, Dummies, borrowers and brokers need feedback and encouragement!  When you use C-Loans.com, our online form takes just eight minutes to complete.  Within minutes, if your deal is do-able, hungry lenders will be chasing you with calls and emails. 

But if your commercial loan request is a dud, no one will call you.  You will get nothing but turndown emails.  But at least now you know.  You wasted no more than eight minutes.

Dot-com stocks suddenly crashed.  The fifteen commercial mortgage portals competing against us suddenly had to show a profit.  Ha!  All fifteen competing portals had received at least $1 million in funding.  I doubt any of them ever closed a single deal.  

I remember thinking of that situation like it was a dark room full of giants, hacking and slashing at each other.  C-Loans was like a little person in that pitch black room, getting kneed and jostled by the giants, with no one paying any attention to us. 

Suddenly, the room was quiet.  "Hellooo?  I called out.  Anyone still alive out there?  They were all gone.  Probably $25 million in VC capital was burned up.  C-Loans.com went on to close well over 1,000 commercial real estate loans totaling over $1 billion.  We closed two large loans just this past week.

When this next great recession hits, I will be
enjoying $63,000 in monthly servicing income?  You?

Now on to trading, the new hot buzzword used by all of the Big Boys.   We traded this.  We traded that.

Surprisingly, it does not mean, in Big Boys slang, we exchanged this, or we exchanged that.  It simply means we sold this property.

Or it could mean that we financed this big property.  The aspiring Big Boys drop the term whenever they can.

Your real estate license authorizes you to trade in real estate.

Simply put, trading in real estate is acting on behalf of a consumer or investor to buy or sell real property, which includes land and any dwellings attached to or included with the land, such as houses, apartment buildings, condominiums, commercial space and mobile homes. Trading also includes commercial leasing and commercial property management.

Trading does not include residential leasing and property management, selling time shares, businesses without land (like a mobile food truck), business equipment not including land (like hair salon furnishings), facilitating a new construction on already owned land and trailers or mini homes without land.

Are you an accredited investor?