okay, I have searched in BOL and the OTS websites, and I am not finding a clear definition of:

raw land
land development
improved property

and I need a clear definition [with cites] so that I can determine if we are within the supervisory LTV limits and defend my conculsion.

If the purpose of our loan is to purchase raw land, and the owner then developes that land, is it in the land development category?

If the purpose of our loan is to purchase a residential building lot [i.e. a lot that is ready to build upon], is our collateral in the improved property category?

we tried calling the OTS, but they said they would "get back to us" and didn't. I checked the TFR, and we are reporting all our land loans under SC265 for land.

I know that I am sometimes easily confused, but it would seem to me that this should not be quite this difficult!

I would try 12 CFR 560.101 of the OTS Regs for definitions and AL2003-7 which is an OCC advisory letter explaining the land development issue and how it should be defined and treated for supervisory LTV purposes.

560.101 wasn't clear -- I'll try the advisory letter!

thank you

I did not find anything in the advisory letters that helped -- and I have an additional question

in days gone past, we always treated a residential building lot as 1-4 property on the call report. On a TFR, everything is just classified as "land". For the 30% limit, can I consider a residential building lot [not raw land] in the 1-4 category, which means that my limit is not 30% but 100% of risk-based capital?

The OTS put out a Q&A in 1994 that addresses some of your questions regarding how to classify property in different stages of development. Q&A - 3, specifically answers your question regarding a residential lot. OTS Q&A

A residential building lot should be reported on line SC265 of the TFR.