Well, the bank will have a lien on the property, but no-one knows about it, and the borrower can (illegally) have another lien against the land (in violation of the security agreement).
There are various regulations covered by real estate lending. An AOC relieves the bank of only one - an appraisal. Independent Bankers of Texas has a great recap of AOC and the regs.
http://www.ibat.org/legal-ease/2014/1/le...-and-regulatoryIf the borrower otherwise qualifies for the loan and the LO wants just a bit more leverage, (s)he is using the land. To determine whether or not it is allowed, you would have to look to the bank's underwriting guidelines and the loan officer's lending limits.