To the best of my knowledge, a license could be required if the "finder" of the deal is selling or assigning the deal to someone else for a fee. (So this applies if the finder does not retain any ownership interest).
If the "finder" has any ownership in the deal (either legal or beneficial through a JV), then no license is required. So one could construct an RTO deal and then find a money partner for a JV. One could then charge a "finder's fee" in addition to having a share of the deal itself.