We are looking to purchase some individual loans secured by primary residences from a mtg broker (loans will be closed in the brokers name). My question, do the higher priced mtg. rules apply? i.e. do we need to escrow etc.?

It appears you are the investor therefore the HPML requirements apply.

this is not going to make management happy, so is there a place in the reg. I can go for support?

(3) Escrows —(i) Failure to escrow for property taxes and insurance. Except as provided in paragraph (b)(3)(ii) of this section, a creditor may not extend a loan secured by a first lien on a principal dwelling unless an escrow account is established before consummation for payment of property taxes and premiums for mortgage-related insurance required by the creditor, such as insurance against loss of or damage to property, or against liability arising out of the ownership or use of the property, or insurance protecting the creditor against the consumer's default or other credit loss.

If you are servicing them you will need to take over the escrow. If your upstream bank is servicing them than you just need to do due diligence to make sure they are doing it right.

thank you for your help!