We have a similar situation. Commercial multi-family was purchased and not reported because it was temporary (secured by building). Now we are doing what was supposed to be HI but turns out a complete demo so now classified as a construction loan (still secured by building until dozers get to it). Will be interest only then converting to P&I. Is this a refinance? I am getting hung up on the fact it was never reported.
Sounds like 2 phase financing with a temporary phase (interest only) followed by the construction phase. That would be a purchase for HMDA, not a refinance.