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 Additionally, the TDD 1-(800) number referenced in Rulemaking documents attached to this page is obsolete and the 7-1-1 number should be used.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	First Name	Last Name	Organization	Comment
03/16/20			Christian Coalition of America	See attached. Email: N/A 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. Email: N/A Attachment: View Attachment
03/16/20			The 60 Plus Association	See attached. Email: N/A 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
03/16/20	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	Brian	Rodgers	Appraisal Institute	I am submitting on behalf of the Appraisal Institute. Email: brodgers@appraisalinstitute.org Attachment: View Attachment
03/16/20	Chris	Furlow	Texas Bankers Association	See attached. Email: N/A Attachment: View Attachment
03/16/20	Colin	Bishopp	PACENation	Please see attached letter. Email: colin@pacenation.org Attachment: View Attachment
03/16/20	Colin	Bishopp	PaceNation and others jointly	Please see attached. Email: colin@pacenation.org Attachment: View Attachment
03/16/20	Craig	Ferguson	Golden State Finance Authority	Golden State Finance Authority comments on PACE Request for Input, Not… Email: cferguson@rcrcnet.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… Email: dgibbs@fhlbc.com Attachment: View Attachment
03/16/20	David	Spector	PennyMac	Please find PennyMac's response attached. Email: jason.piatt@pnmac.com 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… Email: scramer@naseo.org Attachment: View Attachment
03/16/20	Dawn	Bauman	Community Associations Institute	See attached comments. Email: N/A Attachment: View Attachment
03/16/20	Diana	Dykstra	California and Nevada Credit Union Leagues	See attached. Email: N/A Attachment: View Attachment
03/16/20	Don	Boyd	Ohio Bankers League	Alfred Pollard General Counsel Federal Housing Finance Agency 400 7th… Email: dboyd@ohiobankersleague.com Attachment: View Attachment
03/16/20	Elizabeth	Eurgubian	Credit Union National Association	Please find the attached comment letter from CUNA regarding the RFI No… Email: EEurgubian@cuna.coop Attachment: View Attachment
03/16/20	Erick	Roeser	County of Sonoma	Please see attached comments from County of Sonoma. Email: N/A Attachment: View Attachment
03/16/20	Jeanne	Radsick	California Association of REALTORS	Please see attached comments from the California Association of REALTO… Email: matthewr@car.org Attachment: View Attachment
03/16/20	John	FALK	Tahoe Sierra Board of Realtors	16 March 2020 Federal Housing Finance Agency (FHFA) 400 Seventh Street… Email: jrfintel@outlook.com Attachment: N/A
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	Joseph	Pigg	American Bankers Association	Attached, please find comments from the American Bankers Association f… Email: JPigg@aba.com 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