For a TRID construction loan, the Bank's customer is using land owned by his LLC to complete the construction phase of a personal residence.

The land for the residence is titled with the LLC and will be transferred to the Bank's customer.

If there is an act of transfer or donation, is it correct to assume the TRID purpose is home equity?

Thanks in advance.

If the funds would be for the initial construction and not the purchase or refinance of the land - why would it not be "construction"?

If title transferred prior to my loan, I'd call it construction. However, if the transfer happens at closing of the construction loan, even if there is no 'price', it would be a purchase.

The credit is not financing the acquisition. The transfer of the property is unrelated to the loan.

1026.37(a)(9)(i) Purchase. If the credit is to finance the acquisition of the property identified in paragraph (a)(6) of this section, the creditor shall disclose that the loan is for a “Purchase.”