Some collegues and I were reviewing the Home Owner's Equity Protection Act and could use some clarification on Section 3 Termination of Private Mortgage Insurance Section (f)(1)(B)(i)-(ii) and (2).

We believe section 1 states that for high risk loans in the secondary market PMI shall not terminate until 77 percent of the original value is reached. Is this interpertation correct?

Section 2 states that PMI in connection with a high risk loan in the secondary market shall terminate in accordance with subsection c. Which states where cancellation or termination does not occur PMI may not be required beyond the first day of the month immediately following the date that is the midpoint of the amortization period of the loan.
Does this mean that PMI may not be cancelled until 50% of the loan payments in the amortization schedule have been made. I.e. 30 payments in a 60 payment loan?
How does the 77 percent and midpoint tie together?

Is it simply (or not so simply) stating that if the loan does not reach 80% for cancellation or 78% for termination (77% for high risk) before half of the payments in the amortization period (i.e. 30 of 60)that PMI must be cancelled on the 1st day of the month following the midpoint date as long as the loan is current?

Yes. See you didn't need us afterall.