Undr Iowa Code 502.202(11), a privately held mortgage/note/trust deed would be an exempt transaction, not requiring a securities broker license, if all of the following apply:
a. The note, bond, debenture, or other evidence of indebtedness is offered and sold with the mortgage or other security agreement as a unit.
b. A general solicitation or general advertisement of the transaction is not made.
c. A commission or other remuneration is not paid or given, directly or indirectly, to a person not registered under this chapter as a broker -dealer or as an agent.
Based on your stated facts, you are soliciting to trade mortgage instruments via a general solicitation on the internet, and you intend to earn a commission for doing so. Therefore, you must have a securities broker-dealer license.
Hope this helps.
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