I am assuming you are referring to the 1026.35 requirements.
Regardless of the LTV if a loan is a HPML the escrow account must be maintained for no less than 5 years.
If at the end of 5 years the borrower request cancellation under 1026.35(b)(3)(i)(B) then 1026.35(b)(3)(ii) requires the LTV to be less than 80% and the loan not delinquent or in default.
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The opinions expressed are mine and they are not to be taken as legal advice.