What’s the length of this loan going to be? Sometimes if you have a “one time closing” on a construction to perm and the length of your loan is longer, you can avoid this being a HPML. Have you tested this yet?
Also if you’re going to have Builder’s Risk insurance, who’s name is the insurance going to be held under? The builder or the borrower? I definitely wouldn’t be escrowing for BR insurance if the builder was going to carry it. (I know this might not be the case though.)
Sorry that I’m not exactly answering your question.