Answer:
You don't state whether there will be a transfer of the property to the first user.
If any proceeds from the loan are to purchase the lot it will be subject to RESPA and all the early disclosures will apply.
If the lot is not being purchased from any proceeds of the loan there would be no early disclosure requirements. You would just provide the applicable disclosures at closing.
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First published on BankersOnline.com 4/18/11
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