We have a large home improvement loan that we are disclosing and the customer is anticipating it to take 9 months prior to completion and term out of the perm loan. Is the 60 day delayed settlement disclosure in the Other Considerations section of the LE only allowed to be disclosed on truly new construction? 1026.37(m)(8) references "for construction loans in transactions involving new construction" however I was thinking that disclosure could apply any time settlement would be delayed for an extensive period of time such as in this massive home improvement project.

There is no provision for it other than a TRID construction loan which is new construction. You are free to ask the CFPB that question however. If you do, let us know what they say.

ADN - a home improvement/renovation loan is not a new construction loan.

From 1026.37(a)(9)

(iii) Construction. If the credit is not for one of the purposes described in paragraphs (a)(9)(i) or (ii) of this section and the credit will be used to finance the initial construction of a dwelling on the property identified in paragraph (a)(6) of this section, the creditor shall disclose that the loan is for “Construction.”