I also agree. 226.35 does not state mortgage loans on the consumer's principal dwelling subject to RESPA. It does however state in its Commentary that its escrow requirements will be governed by 3500.17.
Remember Reg Z is requiring this escrow, not RESPA, therefore Reg Z has to exempt the loan and as Jay mentioned there are only certain exemptions mentioned in 226.35 and secured by 25 or more acres is not one of the exemptions.
_________________________
The opinions expressed are mine and they are not to be taken as legal advice.