and the credit request is to build additional buildings to an assisted living facilities? These are not additions to the buildings, but actually new free standing ones. I know the thought is you build once and all else is renovations/improvements but not sure about this scenario.

I think it depends on what the additional buildings will be--will they be living spaces? A cafeteria? It's hard to say without knowing what the buildings will be. If actual "dwellings" (as defined by HMDA) are being constructed, i would call that a purchase. If the buildings being built are just 'support' buildings for the facility, it sounds more like "improving the real property on which the dwelling sits"--home improvement.

The new buildings will be expanding the number of beds for the Assisted Living Facilities.

It sounds like a purchase to me, but i will gladly defer to someone with more experience with assisted living facility lending--have never had one here.