If you're the first lienholder and there's no one behind you, why don't you do a simple construction-only loan under a second mortgage? When the funds are fully advanced and the construction note matures, then refi the two together. If the borrower want's to start making higher payments now, you can modify the existing mortgage note with no need for TIL disclosures. The construction loan disclosures can be calculated using Appendix D. When you do the final refi, it will disclose like any other mortgage loan.
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...gone fishing.