I would say no. This would be similar to having a building of nominal value on the property. The Mandatory Guidelines indicate that:
"Similarly, if the purpose of a loan transaction is to facilitate the purchase of land for subsequent development, and any improvement on the real property is of nominal value, the wording of the mortgage must specifically exclude the building as part of the security for the loan in order to avoid the mandatory purchase requirement."
I think I have also previous read about the specific instance your describing, but can't put my finger on it.
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