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The Financial Case

Reported values describe the filing ledger. They are not a current market appraisal.

By Oran Jackson · Published October 11, 2026 Originally published on LinkedIn

The money is the message

Foreign persons reported $86.13 billion in current value across 47.24 million acres of U.S. agricultural land in the 2024 AFIDA file — nearly double the acreage and more than double the reported value of 2010. That financial footprint is itself the national-security case: tens of billions of dollars of foreign capital embedded in the land base of a country whose own government now calls farm security national security.

Five entries:

  1. The scale is large and growing. Reported current value rose from $36.20 billion (2010) to $86.13 billion (2024), a 138% increase, while reported acreage rose 90%.
  2. Purchase-price coverage is incomplete. In 2024, 59.9% of records carried a zero or blank Purchase Price — up from 33.6% in 2010. Purchase Price, Current Value and Estimated Value are separate fields; absence in one does not establish absence in the others.
  3. The values refer to filing time. USDA defines Current Value as "value at the time of filing." The reported-value-per-acre series rose 25% while the NASS national benchmark rose 94%. These series cover different interests and land mixes and are not directly comparable appraisals.
  4. The adversary framing captures ~1% of the money. China-coded holdings total $0.92 billion — about 1.1% of reported value. The remaining reported value covers other country codes and codes 998 and 999. The financial case does not depend on who the buyer is.
  5. The concern is interdepartmental, not one agency's talking point. USDA, Defense, Homeland Security, Justice, Treasury (CFIUS), and the GAO are all on record treating foreign farmland as a security matter — yet the financial data feeding those departments arrives once a year, on a paper-derived ledger with zero or blank Purchase Price in six in ten records.

$36 billion → $86 billion

Computed from the cleaned AFIDA holdings files, 2010–2024. Purchase Price and Current Value are filer-reported fields; the 2010–2012 files record values in thousands of dollars (corrected here).

The headline ratios: +90% reported acres, 2010 → 2024; +138% reported current value; +25% implied value per acre. The purchase-price sum includes recorded positive prices; missing values and legitimate zero-consideration transfers require separate review. It is not a current-market valuation or a demonstrated lower bound on that valuation. Record counts are administrative filings, not parcels.

Six in ten records have no usable purchase price

The share of 2024 records with a zero or blank purchase price is 59.9% — up from 54.3% (2020), 36.6% (2015), and 33.6% (2010). The disclosure regime is losing its grip on pricing even as the footprint it tracks nearly doubles.

What "zero" can mean: fairness requires the caveat — a $0 purchase price is not always suspicious. Inheritances, gifts, intra-company transfers, and corporate restructurings can legitimately report no consideration. The file does not reliably distinguish a gift from a gap. But that is itself the indictment: a disclosure system that cannot distinguish a legitimate $0 transfer from a missing price — for 29,683 of 49,548 records in 2024 — is not producing a price signal. It is producing a ledger with six-tenths of the prices torn out.

The honest math: the $46.58B 2024 purchase-price sum comes from only the 40.1% of records with a positive price. The median price per acre among records with a price is $1,719 (median, not mean, because a small number of extreme per-acre values distort the average beyond use).

Why it matters for enforcement: AFIDA's civil penalties scale with fair market value — up to 25%. A missing purchase price does not prevent an assessment: other reported value fields or independently obtained valuation evidence may be available. The relevant interest, valuation date and fair market value must be established separately.

The ledger reports filing-time values

USDA's field key defines Current Value as "value at the time of filing." The acquisition year is not necessarily the filing year, and this review does not establish whether a particular record was later updated. The result: AFIDA's implied value per acre rose 25% from 2010 to 2024 — while USDA's own market benchmark, the NASS farm-real-estate series, rose 94% over the same period.

Filing-time values are not automatic market updates. Differences from NASS averages may also reflect geography, land use, the interest reported and the records included. These comparisons do not establish that $86.13 billion is a lower bound on present market value.

Reality check by land use (assigning each 2024 record's value to its dominant land use, approximate): crop-dominant foreign-held land is carried at $2,575/acre against the $5,570 NASS cropland benchmark; pasture-dominant at $1,101 against the $1,830 pasture benchmark.

$86 billion, and $10.7 billion with no country attached

By reported current value, the money is overwhelmingly allied-country capital — Canada alone accounts for $18.02 billion on 16.13M acres. The Netherlands: $8.48 billion. Germany: $7.18 billion. The United Kingdom: $5.26 billion. Italy: $4.78 billion. Japan: $4.17 billion. France: $3.21 billion. Denmark: $3.02 billion.

And more than $10.7 billion sits in records coded "no foreign investor listed" (998, 1.38M acres, $7.77B) or "no predominant country code" (999, 1.55M acres, $2.94B): these two source categories do not assign a single predominant country in this summary. They do not establish that all underlying investor information is absent.

The 1% problem: China-coded holdings are $0.92 billion — about 1.1% of reported value. All four commonly cited countries of concern together are roughly 1.1%. The adversary-centered security framing, taken on the money alone, addresses one dollar in a hundred. The balance includes other country codes and $10.71 billion under codes 998 and 999; it should not all be classified as allied capital.

"AFIDA Watch's position is that any country's purchase of American farmland is a sovereignty matter — not only adversaries'. The ledger supports that framing structurally: $86 billion of foreign capital is embedded in the U.S. land base regardless of flag, six in ten records have zero or blank Purchase Price, filing-time values are not market updates, and one dollar in eight falls under codes 998 or 999."

Presented as the publisher's thesis — distinct from the U.S. government's adversary-focused framing and from the documented figures above.

Six federal bodies agree on the problem. The ledger still doesn't add up.

The foreign-farmland concern is not one agency's talking point. It is established across the federal government — which sharpens the accountability question: with this many departments on record, why does the financial disclosure at the center of it still fail at its most basic job?

USDA — the disclosure owner: administers AFIDA; publishes the annual holdings reports. On July 8, 2025, Secretary Rollins announced the National Farm Security Action Plan, declaring farm security national security and promising AFIDA modernization, geospatial data, higher penalties, and a CFIUS coordination agreement.

Defense — the co-announcer: Secretary Hegseth stood with Rollins at the July 2025 announcement; USDA and Defense later signed an MOU implementing the plan's farmland-security provisions.

Homeland Security — the infrastructure lens: food and agriculture is designated critical infrastructure.

Justice — the prosecutor: Attorney General Bondi co-announced the 2025 plan. DOJ has brought agroterrorism-related prosecutions, including charges against foreign nationals for smuggling a crop-damaging fungus — the case the plan cites as its trigger.

Treasury (CFIUS) — the transaction reviewer: under FIRRMA (2018), CFIUS reviews certain foreign real-estate transactions for national-security risk. But GAO found USDA shares AFIDA data with CFIUS once a year, from a paper-derived process — the reviewers deciding on land deals work from a stale, once-annual spreadsheet.

GAO — the auditor: the January 2024 report (GAO-24-106337) found USDA's processes to collect, track, and share AFIDA information "flawed": paper forms, data-entry errors, double counting, and no timely sharing with national-security agencies.

What $86 billion of foreign capital means on the ground

The reported foreign-linked interests form a substantial footprint. This analysis does not establish their share of total U.S. farmland market value; doing so requires a compatible national denominator and valuation basis. Record land values ($4,170/acre nationally in 2024, up 94% since 2010) price out beginning farmers while the foreign footprint nearly doubles.

What the data support: foreign-held acreage grew 90% in fifteen years while U.S. farm real-estate values nearly doubled — foreign capital is accumulating land through the steepest appreciation run in modern farm history. The median reported purchase price ($1,719/acre, among records with a price) sits far below current market — a comparison that requires acquisition dates, interest types and local market evidence before drawing conclusions about appreciation received by particular holders. Cash rents hit records alongside values ($160/acre cropland nationally in 2024), raising operating costs for the tenant farmers who compete against capitalized owners.

What the data do not prove: these records cannot establish that foreign buying caused local price increases. Causation requires parcel-level transaction analysis against local benchmarks — not done here. High foreign-held acreage in a county does not identify which buyers, at what prices, or with what financing. Allied-country capital (the great majority) and adversary capital are different policy questions; this report does not conflate them.

Five findings, five tests for the ledger

  1. The $86.13 billion total is reported Current Value, not a present-market appraisal. Separately, 59.9% of records have zero or blank Purchase Price, and $10.7 billion falls under country/source codes 998 or 999. Test: require purchase price or consideration on every filing; publish the zero/blank share as a data-quality metric in each annual report.
  2. The ledger cannot track the market by design. "Value at the time of filing" does not automatically track market changes; implied $/acre rose 25% while the market rose 94%. Test: require periodic marked-to-market revaluation or indexed updating for holdings above a threshold; disclose the methodology.
  3. The money is 99% non-adversary. China-coded holdings are ~1.1% of reported value; allied and unattributed capital dominate. Test: frame policy around the full foreign footprint, not only the adversary slice — or state explicitly why the 99% is acceptable.
  4. Six federal bodies agree; the ledger serves none of them well. USDA, Defense, DHS, Justice, Treasury/CFIUS, and GAO are on record — yet CFIUS gets the data once a year. Test: deliver AFIDA data to CFIUS and the public on a transaction-time feed, with geospatial identifiers, as the 2025 plan promised.
  5. Penalties need prices. A zero or blank Purchase Price does not establish that fair market value is unavailable. Other value fields and independent evidence require review. Test: publish assessed and collected AFIDA penalties annually with the valuation basis for each — the companion penalty report tracks this test.

The mirror test

Six federal bodies of the United States government have said, in their own words and on their own letterhead, that foreign farmland is a national-security matter. They were right — and this ledger, for all its gaps, proves the scale of what they described: $86 billion in foreign capital holding 47 million acres, measured in a filing ledger where six in ten records have zero or blank Purchase Price, a separate field from Current Value. This series holds up that mirror. The next move belongs to the institutions that made the declarations.

METHODOLOGY NOTE: AFIDA Watch findings are built from publicly disclosed federal records. Fifteen cleaned holdings files (2010–2024, one per year) were parsed as records. Purchase Price and Current Value were summed as filer-reported dollars, except 2010–2012, whose file headers record values in thousands of dollars — corrected by ×1,000. "Zero/unreported purchase price" counts records where the field is blank, non-numeric, or literal zero. China figures use country code 156. NASS figures are from USDA's Land Values 2024 Summary (August 2024). A $0 purchase price can be legitimate (inheritance, gift, restructuring); the file does not reliably distinguish legitimate zeros from missing data. Causation between foreign buying and local land prices is not established here. Keep sums of reported fields distinct from market valuations; missing Purchase Price alone does not establish a lower bound on Current Value or fair market value. Distinguish the publisher's thesis (any foreign farmland purchase is a sovereignty matter) from documented fact and from the U.S. government's adversary-focused framing. No private AFIDA Watch scoring system, tier, weight, flag, or derived map was used or disclosed. This publication makes no legal conclusions.

Editorial clarification · October 24, 2026: Purchase Price, Current Value and independent fair market value have been distinguished. The reported sums are not presented as current-market lower bounds; a missing purchase price does not establish that penalty valuation is impossible.

Sources

  1. Cleaned holdings files afida_current_holdings_yr2010_clean.csv through afida_current_holdings_yr2024_clean.csv. All acreage and value computations derive from these files. Descriptive use only.
  2. USDA field key: foia_key_afida_data_fields_2016_and_forward_yrs.pdf — defines Current Value as "value at the time of filing."
  3. USDA NASS, Land Values 2024 Summary (August 2024).
  4. GAO-24-106337 (January 18, 2024).
  5. USDA, National Farm Security Action Plan announcement (July 8, 2025).
  6. FIRRMA (2018).
  7. 7 CFR 781.4 — AFIDA civil penalties and valuation basis.
  8. AFIDA Watch Article No. 1, H.R. 2 and Foreign Agricultural Land Ownership (September 2026).

DISCLAIMER: This article is a policy research product, not legal advice, not an appraisal, and not a finding of wrongdoing. Its strongest use is as an evidentiary basis for oversight questions, data-quality demands, and farm-bill drafting — and as the financial companion to this series' penalty and accountability reports.