Answer:
If the home improvement loan is temporary (plan to refinance into a permanent type loan), then while it would be a HPML, it would be exempt from escrows under 1026.35(b)(2)(i)(C).
If the home improvement loan is temporary (plan to refinance into a permanent type loan), then while it would be a HPML, it would be exempt from escrows under 1026.35(b)(2)(i)(C).