If a lot is refinanced (within 2 years from purchase) by the initial draw from a construction loan, does RESPA apply? I know the two year rule applies if loan proceeds are used for the constuction of the dwelling, but the reg is vague as to proceeds of which loan--the original obligation or any loan proceeds used in connection?

No, if you are refinancing the lot there is no transfer to the first user in your transaction. (I am assuming this is a construction loan only where you will not be doing the permanent.)