I will assume you send your notice in Dec. and I also assume (since it is not defined) that annually is from the date the mortgagor obtained the PMI. If you wait until Dec. 2008 that is 16 months from the opening date of the loan, therefore you did not provide an annual notice.
We too send our notices in Dec. and any loan closed through 11/30 gets a notice. It may be overkill but we are providing to each mortgagor an annual statement at least within 12 months of the account opening and every 12 months thereafter.
The opinions expressed are mine and they are not to be taken as legal advice.