Appraisal needed or business loan exemption

Would this qualify for a business exemption -
New loan for construction to business to renovate and improve hotel - loan amount of $850,000. Loan is being presented based solely on the wages from the borrowers with no income from the RE or the property. There is no operating cash flow from the hotel as it has not been in operation. Once construction is completed, a full appraisal would be obtained to term out the loan. Would this qualify for the exemption?

A business loan with a transaction value equal to or less than the business loan threshold of $1 million, and is not dependent on the sale of, or rental income derived from, real estate as the primary source of repayment is exempt.