I think I know the answer, but want to be sure I'm not missing something...

We have an existing loan to a customer on their residence. There is a LOMA on the residence, but the LOMA does not include the existing detached buildings.

The customer has applied for a construction loan to build a new detached garage on the property. The garage is for personal use and not ag or commercial use. For collateral purposes, we do need the garage as collateral on the loan.

Does the detached structure exemption apply under 339.4 even when it is a new construction and not an existing structure?

Yes - if the new structure qualifies under the detached structure definitions, then it will be exempt.