Early Disclosures for 2nd Loan to Purchase Primary

We have a customer that is purchasing a primary residence and they are wanting a 2nd loan using 23 acres of recreational land as collateral for their down payment money to purchase the residence. We are unsure to what early disclosures we would need to have since the purpose of the 2nd loan is to purchase a primary residence. Plus, the officer is wanting to cross collateralize these two loans. Since the 2nd loan has only land of 23 acres as collateral and the documents are purpose driven to purchase a primary residence we are not sure how RESPA applies?