Answer:
It sounds like this loan is for neither a consumer or business purpose, but rather an agricultural purpose. The Reg. Z exemption for agricultural purpose loans is NOT a subset of the exemption for business or commercial purpose loans. Two years ago, we had an exhaustive discussion of the agricultural exemption, here. Stop looking at collateral values as indicators of purpose, study that thread, and look for the answer to your question in Section 1026.3(a), Official Interpretation #8.