HMDA - exempts construction only and other temporary financing. Construction/perm loans are not exempt but this does not appear to be a construction/perm loan.
RESPA - exempts temporary financing except for construction loans where the construction loan may be converted to permanent financing by the same lender or transfer of title to the first user. Again this loan does not appear to be a construction loan.
FWIW, I would look at this loan as a bridge loan and consider it temporary financing. Even if the bank wound up taking the permanent mortgage, this interim loan, IMO, would still be considered a temporary loan. The bank is reasonably contemplating the loan to be paid from other financing arrangements.
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The opinions expressed are mine and they are not to be taken as legal advice.