Property Assessed Clean Energy (PACE) Program

FOR FURTHER INFORMATION CONTACT: Alfred M. Pollard, General Counsel, Alfred.Pollard@fhfa.gov, (202) 649–3050 (this is not a toll-free number), Federal Housing Finance Agency, 400 Seventh Street SW, Washington, DC 20219. If you are deaf, hard of hearing, or have a speech disability, please dial 7-1-1 to access telecommunications relay services. Additionally, the TDD 1-(800) number referenced in Rulemaking documents attached to this page is obsolete and the 7-1-1 number should be used.

SUMMARY: The Federal Housing Finance Agency (FHFA), as regulator for Fannie Mae and Freddie Mac as well as the Federal Home Loan Banks, seeks public input on residential energy retrofitting programs financed through special state legislation enabling a ‘‘super-priority lien’’ over existing and subsequent first mortgages. In particular, FHFA seeks input on potential changes to its policies for its regulated entities based on safety and soundness concerns. These state programs, termed Property Assessed Clean Energy or PACE, address residential properties and commercial applications. FHFA’s primary focus is on residential PACE programs in this Request for Input (RFI).

DATES: Written input must be received by March 16, 2020.

Public Comments

Below are a compilation of public comments made on this notice.

61 items

CSV

Date Sort ascending	First Name	Last Name	Organization	Comment
03/16/20	Ron	Haynie	Independent Community Bankers of America	Please see attached comment letter.View Comment Email: ron.haynie@icba.org Attachment: View Attachment
03/16/20	R.J.	Lehmann	R Street Institute	Attached are comments from R.J. Lehmann, director of finance, insuranc…View Comment Email: rlehmann@rstreet.org Attachment: View Attachment
03/16/20	Steven	Gottheim	American Land Title Association	Please see the attached comments of the American Land Title Associatio…View Comment Email: sgottheim@alta.org Attachment: View Attachment
03/16/20	Dana	Gibbs	Federal Home Loan Bank of Chicago	We appreciate the opportunity to present the attached response to the…View Comment Email: dgibbs@fhlbc.com Attachment: View Attachment
03/16/20	Brendan	Kihn	U.S. Mortgage Insurers	Please see the attached comment letter on behalf of U.S. Mortgage Insu…View Comment Email: N/A Attachment: View Attachment
03/16/20	Linda	Jun	Americans for Financial Reform Education Fund	Please disregard my last submission and update it with this corrected…View Comment Email: linda@ourfinancialsecurity.org Attachment: View Attachment
03/16/20			Renew Financial Group LLC, PACE Funding Group LLC, FortiFi Financial Inc., and Renovate America Inc.	See attached joint letter with attachments.View Comment Email: N/A Attachment: View Attachment
03/16/20	David	Spector	PennyMac	Please find PennyMac's response attached.View Comment Email: jason.piatt@pnmac.com Attachment: View Attachment
03/16/20	Brendan	Kihn	Joint Comment Letter	Please see attached for comment letter on behalf of California MBA, CU…View Comment Email: N/A Attachment: View Attachment
03/16/20	Colin	Bishopp	PACENation	Please see attached letter.View Comment Email: colin@pacenation.org Attachment: View Attachment
03/16/20			Christian Coalition of America	See attached.View Comment Email: N/A Attachment: View Attachment
03/16/20	Stacey	Tutt	California Low-Income Consumers Coalition	Please see accompanying letterView Comment Email: stutt@law.uci.edu Attachment: View Attachment
03/16/20			The Credit Officer’s Group of the Federal Home Loan Banks	See attached.View Comment Email: N/A Attachment: View Attachment
03/16/20	Adam	Pugh	NACo and NLC	See attached.View Comment Email: apugh@naco.org Attachment: View Attachment
03/16/20	David	Terry	National Association of State Energy Officials	Alfred M. Pollard General Counsel Federal Housing Finance Agency 400 S…View Comment Email: scramer@naseo.org Attachment: View Attachment
03/16/20	Tom	Kirk	Coachella Valley Association of Governments	Coachella Valley Association of Governments comments on PACE Request f…View Comment Email: tkirk@cvag.org Attachment: View Attachment
03/16/20	Don	Boyd	Ohio Bankers League	Alfred Pollard General Counsel Federal Housing Finance Agency 400 7th…View Comment Email: dboyd@ohiobankersleague.com Attachment: View Attachment
03/16/20	Keith	Thornburg	Missouri Bankers Association	see comment letter and attachments for two examples of consumer abuse…View Comment Email: kthornburg@mobankers.com Attachment: View Attachment
03/16/20	John	Rao	National Consumer Law Center, Inc.	Please see attached comments from the National Consumer Law Center (o…View Comment Email: jrao@nclc.org Attachment: View Attachment
03/16/20	Joseph	Pigg	American Bankers Association	Attached, please find comments from the American Bankers Association f…View Comment Email: JPigg@aba.com Attachment: View Attachment
03/16/20	Diana	Dykstra	California and Nevada Credit Union Leagues	See attached.View Comment Email: N/A Attachment: View Attachment
03/16/20	Mike	Lemyre	Ygrene Energy Fund	See attached.View Comment Email: mike.lemyre@ygrene.com Attachment: View Attachment
03/16/20	Brian	Rodgers	Appraisal Institute	I am submitting on behalf of the Appraisal Institute.View Comment Email: brodgers@appraisalinstitute.org Attachment: View Attachment
03/16/20	Dawn	Bauman	Community Associations Institute	See attached comments.View Comment Email: N/A Attachment: View Attachment
03/16/20	Robert	Giles	PACE Funding Group, LLC	Please find attached the response to FHFA RFI Notice No 2020-N-1 from…View Comment Email: bob@pacefunding.com Attachment: View Attachment