Am I correct in thinking a 2nd home should be reported as NA on the LAR for HOEPA? Our system is not defaulting to this so I am second guessing myself. Section 32 only applies to primary dwelling correct?

Yes. Section 32 only applies to a principal residence.

"(a) Coverage. (1) The requirements of this section apply to a high-cost mortgage, which is any consumer credit transaction that is secured by the consumer's principal dwelling, other than as provided in paragraph (a)(2) of this section, and in which..."

Thank you once again Adam! I always appreciate your feedback!

In addition to the above, should we also be reporting the rate spread as NA?

Rate spread is to be reported on all consumer purpose loans. IOW, if there's an APR, disclose the rate spread.

Our system is also screwing this up, so I manually had to adjust all originated and ANA non-principal dwelling originated loans to code 3- NA and all incomplete, denied, or withdrawn loans to code 3.