It's been a while since I was asked this specific question and i can't recall what I stated in the past. Today, I am thinking that a purchase sounds reasonable as the funds are going directly to the contractor to pay for the "newly constructed primary dwelling." I view this similar to the end financing of a temporary loan - where the contractor is essentially the lender in this case.
Others may disagree, so I will be interested to see what they say about this topic that is not exactly addressed by the rules.
_________________________
Adam Witmer, CRCM
All statements are my opinion, not those of my employer, and should not be taken as legal advice.
www.compliancecohort.com