Appraisal Requirements on Builder Loans

I know this has been discussed in previous post but I am needing some help. My CCO feels that the regulation does not apply to commercial construction loans to builders to construct 1-4 dwellings. I say that the new regulation does apply. What can I use as my support to this. I am going to have to present this to upper management and need to get all my ducks in a row. Thank you!

There is no exclusion for that purpose. If it's a 1-4 dwelling, it's covered by this rule.

Thanks RR Joker!