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One of my best loan officers just advised me that she can do a cash-out refinance of a 1-4 unit investment property even if you have up to 10 financed investment properties. Maximum loan-to-value is 75% on a single-family rental property and it is 70% loan-to-value on 2-4 unit apartment properties. Most lenders can only finance if you have 6, or fewer, FNMA/FHLMC loans.