After some research on HMDA getting it right. I'm concluding it's not reportable. I think the key element is "home improvement by the institution". Since there no existing dwelling at the time the loan funded then we will not identify as a home improvement. I'm I on the right track. I'm hoping we only have one of these types of loans so at least I can meet the be consistent rule.
Home Improvement loan is (a) any dwelling -secured loan to be used, at lease in part, for repairing, rehabilitatinf, remodeling, or improving a dwelling, (or the real property on which the dwelling is located) or (b) any loan not secured by a lien on a dwelling to be usedm at least in part, for one ot more of those purposes that is classified as a home improvement loan by the institution.