Borrower bought a home a few years ago. It was an HPML, we haven't reached the end of 5 years. He recently lost his wife and wants to downsize and move closer to family. He has another home in mind, but won't be selling/paying off the 1st loan. So, he's applied for a new loan to purchase a primary dwelling. The ATR is there, I'm not worried about that, but the new loan will also be an HPML. He'll have to escrow on this home loan too - won't he?