No. The new definition of higher-priced mortgage loan in 1026.43 only applies to that section (1026.43). The definition in 1026.35 is still the same (ie there is no distinction for small creditors with a separate threshold).
The only thing the new threshold in 1026.43 did was to give small creditors the safe harbor on QMs orginated under that type, instead of just a rebuttable presumption of compliance, for loans priced up to 3.5 over APOR. It does not affect the escrow requirements. So if you originate a first lien small creditor QM that is priced 2.0 over APOR, you get the same protections as a non-HPML QM (safe harbor), BUT you would still have to escrow.
I can't herd the cats anymore, so I just set up the electric fences and let them fry when they stray out of bounds.