Correct me if I'm wrong:

Consumer purpose loan secured by subordinate lien on primary residence.

Loan is to finish bsement and will be closed end, multiple advance...

Wouldn't the loan officer use Appendix D for the calculations as if it were a construction loan although it is simply a multi-advance loan to finish a basement and not new construction?

yes...same principal...the driving factor is the multiple advance closed-end.

so do the same early disclosures apply as if it were closed end, no multiple advance?

How you calculate the APR wouldn't have any effect on what disclosures you give.

2nd lien, home improvement = GFE

Gotcha, thanks!

Plus the fact that you do not know the dates and amounts of draws at the time the TIL must be delivered. You would not use App. D in cases where you do know the schedule of advances.