I thought I found a previous discussion on this topic yesterday, but cannot find it this morning. I apologized if this is duplicate question.

Two loans. First loan is to take equity out of their current primary residence for a down payment of a new primary residence, secured by the current primary residence. Second loan, purchasing a new primary residence secured by the new primary residence. Neither loans will be temporary

On the "downpayment" loan does HPML apply? It is their current principal residence, but it will be a second home or rent house after the closing of the "purchase" loan. I know right of recession applies, but I'm unsure about the escrow requirement.