Rate Spread HMDA/Reg C: Apply to Construction?

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Question:

Does the rate spread under HMDA Reg C apply to construction loans for residential 1-4 family?

Answer:

Yes. Here's our summary of this requirement:
Report the rate spread (as of the date the interest rate was set) between the APR and the “Average Prime Offer Rate” to at least 3 decimal places. [§1003.4(a)(12)(i)] If the loan/line is not subject to Regulation Z or not originated (except approved but not excepted) enter “NA”. [Commentary to §1003.4(a)(12) #7]