I hope in your case that your borrowers are not using the money for personal, family, or household uses.The Official Staff Interpretations for Reg Z (Dodd-Frank) specify your exact scenario in at least two ways: Section 226.3 - Exempt Transactionsii.

People don't just start staying at your hotel within two weeks of rehab, it takes marketing, sales effort, retraining of staff, etc.

When you get a contract, be sure to include a contingency that you need to inspect the Code Enforcement file and get approval from your "investor group"  (person you will wholesale to).Make friends with the Code Enforcement staff.  

@Patrick Britton the worse part of the meeting were the side comments from the support staff.

An in-house repair staff is just another profit center to the property manager.

This is, after all, the website that once had a staff post about buying a house completely with credit cards!

If they do not, I would strongly shy away as they do not really understand the emphasis and focus the company needs to put on getting that vacant property occupied (with good tenants of course).The focus of most management companies is on mitigating risk and on finding and keeping staff. 

Seems the takout/delivery model would be more viable moving forward, and would save a ton of resources with no retail, high visibility location, much smaller footprint, delivery personnel instead of wait staff, no dishes to clean, etc. 

Usually, they have attorneys on staff to help with these situations.

On a separate note:  Thanks to the bigger pockets staff and the resources on this website and podcast.