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  • Comment Detail

  • Date: 01/28/20
    First Name: Jackie
    Last Name: Young
    Organization: Fibre Federal Credit Union
    City: N/A
    State: N/A
    Attachment: N/A
    Number: 2020-N-1

  • Comment

    Super-priority liens should not be allowed for this program. We are making first mortgage loans in good faith dependent on our underwriting criteria and should not have PACE liens come in in front of us after originating the loan. If we go into a foreclosure situation, we would be required to payoff the PACE loan to collect on our loan. We have no guarantee of full repayment of a loan when we make a loan. Why should PACE loan have that guarantee. Our underwriting requirement is to not go over 80% LTV without mortgage insurance. Super-priority liens for PACE would take away part of our ability to accurately underwrite and secure our loans. We would have no control over these liens and would not know they were in front of us until the loan was delinquent.