I have read through the threads here and looked at the OCC handbook on HOPA. I see where it says that mortgages on second homes with PMI do not get annual disclosures...however I see no distinction when it comes to the initial PMI disclosure. This is a FNMA loan that is a second home. Am I correct in thinking that because it doesn't not say specifically primary residence that we need an initial PMI disclosure and Amort Schedule for this loan? Thank you.

HOPA only applies to the consumer's principal dwelling.

Look for the definition of Mortgage Transaction and Residential Mortgage transaction in Sec. 4901.