HPML and escrow

I was asked a question the other day that I think I know the answer too, but I can't find anything to support it.

If we make an HPML between 10/1/09 and 3/31/10, we won't need to start escrow on those loans come 4/1/10 correct? Escrow would only be required for loans originated on or after 4/1/10? In essence, we have a period of 6 months that we only have to comply with the other restrictions (repayment ability, prepayment penalties)?

Nevermind...found a reference to this in the preamble to the final rule. Excuse my premature posting

Where was the reference and what was the answer?

In the final rule, the preamble before the actual changes to Reg Z, it states:

The final rule requires escrows for all covered loans secured by site-built homes for which creditors receive applications on or after April 1, 2010 , and for all covered loans secured by manufactured housing for which creditors receive applications on or after October 1, 2010.