Read the ladder as a statement about collateral, not about borrowers. Bare land produces no income, cannot be occupied, and has no building whose cost to rebuild anchors a valuation. Comparable sales are thinner and older than for houses, so two appraisers can reach genuinely different figures. If the borrower stops paying, the lender is left holding an asset that generates nothing while it waits for a buyer. Every difference a borrower encounters, the larger cash contribution, the shorter term, the closer scrutiny of what the parcel is for, follows from those facts rather than from any rule requiring them.
The framing of those percentages matters as much as the numbers, and it is routinely inverted. They are limits on what an institution's own internal policy should allow, not caps on any individual loan. The same appendix says "it may be appropriate in individual cases to originate or purchase loans with loan-to-value ratios in excess of the supervisory loan-to-value limits, based on the support provided by other credit factors", with those loans identified in the institution's records and their aggregate amount reported at least quarterly to the board. It then caps the aggregate of all such loans at 100 percent of total capital, and within that caps loans on commercial, agricultural, multifamily and other non-1-to-4-family property at 30 percent of total capital. It also carries an Excluded Transactions list, covering among other things loans guaranteed or insured by the federal government to the extent of the guaranty, loans sold promptly without recourse to a financially responsible third party, and renewals or restructurings without the advancement of new funds. "The law caps a raw land loan at 65 percent" states the position backwards.
The guidelines split what buyers call one thing into two, and the line is infrastructure. A "[l]and development loan means an extension of credit for the purpose of improving unimproved real property prior to the erection of structures", and the improvement "may include the laying or placement of sewers, water pipes, utility cables, streets, and other infrastructure necessary for future development." A construction loan, by contrast, is credit "for the purpose of erecting or rehabilitating buildings or other structures, including any infrastructure necessary for development", and an improved property loan is secured by completed, income-producing or non-owner-occupied property of the listed kinds. Raw land is the category the guidelines rank first and, in the text read here, do not separately define, which is consistent with its being the residual: land that is neither being improved nor built on. The market's own gradation tracks this loosely. A lot loan for a recorded, serviced building lot with utilities at the boundary is a different proposition from acreage with no road frontage, and it is usually treated as one, but the phrase is a market term rather than a defined category.
What the collateral is for changes the analysis. A parcel bought to build on soon is on a path toward a construction loan and then a mortgage, and each step up that ladder is a step toward better terms. A parcel bought to hold is a speculative asset carried with cash: property tax, insurance where available, and whatever maintenance the land needs, with no rent and no depreciation deduction against it. Where the loan funds multiple phases of one project, the guidelines say "the appropriate loan-to-value limit is the limit applicable to the final phase of the project funded by the loan", while disbursements "should not exceed actual development or construction outlays".
The questions worth answering before the loan, not after. Whether the parcel is legally buildable at all, which is a zoning and permitting question rather than a lending one; whether utilities and legal access exist or must be created, which is the difference between the two categories above; whether any rights over the parcel are held by someone else; and what the survey and the title work show. A lender's caution about bare land is a compressed version of the same list, which is why a borrower who can answer it usually finds the financing conversation easier.