The undersigned organizations wrote in strong support of the Bureau’s proposed rule applying Regulation Z to Residential Property Assessed Clean Energy (PACE) loans. In the proposed rule, the Bureau correctly recognizes that PACE financing fundamentally acts as mortgage credit, yet is provided by underregulated or unsupervised entities that often exploit the lien priority granted to tax assessments. As a result, residential PACE financing should be subject to the same regulations that apply to first-lien mortgages. The rule, if enacted, will significantly limit the well-documented abuses that have occurred in states with active residential PACE programs.
- American Bankers Association
- Center for Responsible Lending
- Consumer Action
- Consumer Bankers Association
- Consumer Federation of America
- Credit Union National Association
- Housing Policy Council
- Independent Community Bankers of America
- Mortgage Bankers Association
- National Association of Federally-Insured Credit Unions
- National Consumer Law Center (on behalf of its low-income clients)
- National Fair Housing Alliance
- National Housing Law Project