Since you're following Part II of Appendix D, is this the requirement you're questioning?
Part II(B)
1. Estimated interest payable during the construction period shall be treated for computation purposes as a prepaid finance charge (although it shall not be treated as a prepaid finance charge for disclosure purposes).
This calculation procedure is designed to collapse the construction period and recast it as an exceptionally long first payment period in an otherwise normal TIL calculation. As explained in paragraph 1, you're only pretending that construction interest is a PFC for calculation purposes. After the calculations are done, you disclose the construction interest in the manner it will actually be paid.
_________________________
...gone fishing.