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 Additionally, the TDD 1-(800) number referenced in Rulemaking documents attached to this page is obsolete and the 7-1-1 number should be used.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	John	Rao	National Consumer Law Center, Inc.	Please see attached comments from the National Consumer Law Center (o… Email: jrao@nclc.org Attachment: View Attachment
03/16/20	Adam	Pugh	NACo and NLC	See attached. Email: apugh@naco.org Attachment: View Attachment
03/16/20	Brendan	Kihn	Joint Comment Letter	Please see attached for comment letter on behalf of California MBA, CU… Email: N/A 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… Email: N/A Attachment: View Attachment
03/16/20	Ron	Haynie	Independent Community Bankers of America	Please see attached comment letter. Email: ron.haynie@icba.org Attachment: View Attachment
03/16/20	William	Spivey	Florida Development Finance Corporation	see attached comments Email: bspivey@fdfcbonds.com Attachment: View Attachment
03/16/20	Lance	Liby	Federal Home Loan Banks	Please see the attached letter. Email: N/A Attachment: View Attachment
03/16/20	Brian	Rodgers	Appraisal Institute	I am submitting on behalf of the Appraisal Institute. Email: brodgers@appraisalinstitute.org Attachment: View Attachment
03/16/20	Keith	Thornburg	Missouri Bankers Association	see comment letter and attachments for two examples of consumer abuse… Email: kthornburg@mobankers.com Attachment: View Attachment
03/16/20			The Credit Officer’s Group of the Federal Home Loan Banks	See attached. Email: N/A Attachment: View Attachment
03/15/20	Brad	Douglas	Heartland Credit Union Association	See up loaded letter. Email: N/A Attachment: View Attachment
03/13/20	Bryan T.	Garcia	Connecticut Green Bank	See attached. Email: N/A Attachment: View Attachment
03/13/20	David L.	Ledford	National Association of Home Builders	See attached. Email: N/A Attachment: View Attachment
03/13/20	Genevieve	Jopanda	California State Treasurer	Please see attached letter. Email: genevieve.jopanda@treasurer.ca.gov Attachment: View Attachment
03/13/20	Toby	Rittner	Council of Development Finance Agencies	Please see the attached letter. Email: trittner@cdfa.net Attachment: View Attachment
03/13/20	Kaley	Schafer	NAFCU	Please see the attached comment letter on behalf of NAFCU. Email: N/A Attachment: View Attachment
03/12/20	Joshua	Buswell-Charkow	California Solar & Storage Association (CALSSA)	See attached. Email: N/A Attachment: View Attachment
03/12/20	Kim	Akin	Mortgage Bankers Association of Missouri	Please see attached letter from the Mortgage Bankers Association of Mi… Email: kim.akin@lgpmconsulting.com Attachment: View Attachment
03/11/20	Michael	Moran	Florida PACE Funding Agency	Email: N/A Attachment: View Attachment
03/10/20	Edward J.	DeMarco	Housing Policy Council	See attached. Email: N/A Attachment: View Attachment
03/10/20	Peter	Grabell	Dividend Finance	Dividend Finance strongly opposes further limitations placed on PACE p… Email: N/A Attachment: View Attachment
03/10/20	Robert	Lameier	Miami Savings Bank	I share FHFA concern the PACE program. However, I believe it would be… Email: rlameier@miamisavingsbank.com Attachment: N/A
03/09/20	Rob	Barrett	Missouri Division of Finance	Please see attached Email: finance@dof.mo.gov Attachment: View Attachment
03/06/20	George	Riley	Conservatives for Clean Energy	See attached. Email: N/A Attachment: View Attachment
03/04/20	Kelly	Price	Eastman Credit Union	See attached Email: N/A Attachment: View Attachment