I meant to include this in my post, as this is what a lot of us are probably waiting for:
From page 6 of the FInal Rule:
"Other commenters recommended exemptions from the escrow requirement for higher-priced mortgage loans. Recommended exemptions included for: (1) loans a creditor holds in portfolio; (2) loans made by community banks; (3) loans made in rural areas; and (4) small retail loans that are first-lien loans because a consumer has paid off his larger mortgage. Such exceptions are outside the scope of this rulemaking. The Board is publishing elsewhere in today’s Federal Register a proposed rule that addresses several of those proposed exceptions."
So, perhaps we will get the clarification we need later today.