Correct - any consumer purpose loan to an individual(s) secured by dirt (bare land, commercial property, residential real estate, etc.) requires the TRID disclosures.
Also - I'm 'assuming' there isn't a structure on the land. In previous lives the loan would be written up this way; however there may have been an old outbuilding on the property, which required a flood determination. Loan officers thought that since the value was in the land that the flood requirements didn't apply.
My Opinions Only