Basically, think of this as two separate transactions, even though the funds themselves are being used to purchase the lot, which may make this a "Home Purchase" under HMDA. However, for TRID purposes, all you have here is a "Home Equity" purpose. It would be similar to the borrower using the funds to go buy a car, or to buy a boat, or any other kind of consumer product. Would you need to disclose the car title, dealer commission, etc. on the LE/CD? No. It's not relevant to the Home Equity loan. It's just how they used their funds.