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Comment

I share FHFA concern the PACE program. However, I believe it would be prudent to determine the scope of the risk before action is taken. Therefore, I am recommending further study to determine the actual level risk. Based on my research it has only enjoyed limited success.

In Minnesota, legislation has been passed which requires PACE loans to be subordinate to the first mortgage or prior recorded mortgages, requires plan language in disclosures, requires ability to repay standards and provides special protections for low-income homeowners.

The Ohio Bankers League is currently working to introduce legislation in Ohio modeled off of the Minnesota bill.

At a minimum a notice should be required of PACE loans to existing lien holders. Lenders may determine it is in their best interest to have a clause in the mortgage which allows to accelerate or demand the mortgage is due to protect their interest.

Adding broad restrictions to the FHLB system to deal with the PACE risk (when the risk is very limited) puts unnecessary penalties on the majority of loans being pledged.

Clearly the PACE program needs to be changed either at the State or Federal level. The PACE program was established for good intentions but has many unintended consequences. Further, many of these problems relate to Consumer Financial Protection Bureau's jurisdiction.

Thank you for allowing me to share my input on this important topic.

Sincerely,

Robert T. Lameier