Proposed Transaction:
Consumer, 12 month interest only (fixed rate) loan, secured by a 1st lien on 9 acres. Following the 12 months, Borrowers will be refinancing the loan and obtaining construction financing from a different institution.

Additional Information:
The land has an "uninhabitable" dwelling on it. I have not seen the dwelling, but the picture on Google Maps, from a few years ago, leads me to believe that someone could live there, even if the roof leaks and the well is currently not working.
Our Borrowers live a few miles away from the land and will be building a new house on this land next year but do not intend to occupy the existing dwelling. It will be demolished, but there is no definite timeline of when.

So - I would appreciate comments on my views of applicable regs.

Flood - Covered
RESPA - I'm leaning toward Exempt, basing that on the fact that this could be considered a bridge loan.
Reg Z (ATR) - Exempt based on this being a "Temporary" loan
Reg Z (HCM) - Exempt based on this not being the principal dwelling.
Reg Z (HPML) - Exempt based on this not being the principal dwelling.
Reg B (Appraisal) - Covered. I don't think there is any type of exemption just because the house is really run down.

Any assistnace or constructive critisicm of my views is eagerly accepted.

I would follow exactly what you have said if this came up in my shop.

Thanks for the review and backing up my thoughts. It's the comment about uninhabitable that got me thinking, but in reality I just treat it as if it is.