This is Robin’s response to the question:
From the information you’ve given it sounds like this loan would be exempt from RESPA/Reg X due to the acreage, but that would not affect coverage under Reg Z. It doesn’t seem to meet any of the Reg Z exemptions; therefore, Reg Z would apply meaning you would need to test for the specific items you mentioned below – section 32, 35, 43 and apply RofR.