We have several instances in which customers are building new homes on land they already own free and clear.

Loans are originally originated as a construction loan and then rolled over into a mortgage (permanent financing)

Is this considered a home improvement since they are improving the real property?

When should this loan be reported on HMDA? When the construction loan is originted or when the mortage/permenant financing is originated?

The fact that the borrowers own the land already is immaterial to HMDA.

And Home Improvement only applies when there is a dwelling on the property and either that dwelling or the property it's on is being improved.

These loans would all be reported as PURCHASES on HMDA at the time that the construction loan is rolled over to permanent financing.