You get the extra 2 points (from 1.5 for a first lien under the HPML rules in Sec. 35) to 3.5 under the small creditor QM rule......so if i'm understanding your question correctly, a loan that meets the "higher-priced" limits under the small creditor exception are naturally going to also be an HPML, so yes, if you have no escrow exemption, you'd need to escrow. To put it more succinctly: if a loan is "higher-priced" under the small creditor QM rules, it will be an HPML....conversely, an HPML under Sec. 35 may not be "higher priced" under the small creditor QM rules.
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