RAW LAND PART 365 SUPERVISORY LIMITS

Chief Compliance Officer at a bank ($326MUSA)

I have been assigned the duty of doing a lending audit. I have the following specific loans that I am questioning in regards to supervisory limits applying to raw land. Does farm ground with no improvements (ie.. irrigation) fall into the 65% raw land bucket? Would a 5 acre tract that currently has no improvements, but has the potential to access county water fall into the 65% raw land bucket?