If the loan is secured by a first lien on a dwelling (your loan fits that description), the appraisal notice and copy requirements of Regulation B section 1002.14 apply. 1002.14(a)
The loan would be exempt from the Regulation Z HPML appraisal requirements as a "transaction to finance the initial construction of a dwelling." 1026.35(c)(2)(iv)
Comply with the Reg B requirement; ignore the Reg Z requirement.
John S. Burnett
Fighting for Compliance since 1976
Bankers' Threads User #8