Is it necessary to escrow on a 9 month construction loan that is testing as HPML? We are closing a 9 mos construction to a 20 yr perm, one closing, and the construction is not for the initial constuction, but for rehab. Reading the reg, I would say yes however the minimal amount that would be escrowed seems irrelevant. Also, is a re-disclosed GFE warranted or if tolerance is acceptable the GFE is a non-issue?