Property Assessed Clean Energy (PACE) Program
| Published date | 16 January 2020 |
| Citation | 85 FR 2736 |
| Record Number | 2020-00655 |
| Section | Notices |
| Court | Federal Housing Finance Agency |
Federal Register, Volume 85 Issue 11 (Thursday, January 16, 2020)
[Federal Register Volume 85, Number 11 (Thursday, January 16, 2020)]
[Notices]
[Pages 2736-2740]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2020-00655]
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FEDERAL HOUSING FINANCE AGENCY
[No. 2020-N-1]
Property Assessed Clean Energy (PACE) Program
AGENCY: Federal Housing Finance Agency.
ACTION: Notice and Request for Input.
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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.
ADDRESSES: You may submit your response on the Notice identified by
``PACE Request for Input, Notice No. 2020-N-1,'' by any one of the
following methods:
Agency Website: www.fhfa.gov/open-for-comment-or-input.
Federal eRulemaking Portal: http://www.regulations.gov.
Follow the instructions for submitting input. If you submit your
response to the Federal eRulemaking Portal, please also send it by
email to FHFA at [email protected] to ensure timely receipt by the
agency.
Mail/Hand Delivery: Federal Housing Finance Agency, Eighth
Floor, 400 Seventh Street SW, Washington, DC 20219, ATTENTION: ``PACE
Request for Input, Notice No. 2020-N-1.''
FHFA will post all public responses received without change,
including any personal information you provide, such as your name and
address, email address, and telephone number, on the FHFA website at
http://www.fhfa.gov. In addition, copies of all responses received will
be available for examination by the public through the electronic
docket for this Notice also located on the FHFA website.
FOR FURTHER INFORMATION CONTACT: Alfred M. Pollard, General Counsel,
[email protected], (202) 649-3050 (this is not a toll-free
number), Federal Housing Finance Agency, 400 Seventh Street SW,
Washington, DC 20219. The Telecommunications Device for the Deaf is
(800) 877-8339.
SUPPLEMENTARY INFORMATION:
Request for Input
A. PACE Programs
The Federal Housing Finance Agency (FHFA), as regulator for Fannie
Mae and Freddie Mac (the Enterprises) 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).
These state initiatives authorize counties, municipalities and
other government entities to create a financing scheme with, in the
majority of cases, private parties administering the home energy
retrofit programs. The programs lend to consumers for defined products
and services and approved contractors. To attract private capital, the
loans impose a tax assessment on the property so that the loan is
repaid under a locality's taxing structure to the benefit of bond
holders or lenders. This assures priority status over any first lien
mortgage at any tax sale or foreclosure sale. PACE is not traditional
second mortgage or home equity lending.
[[Page 2737]]
Each PACE lending program was created to attract private investors
to provide funds for loans for energy retrofits. Unlike normal secured
home improvement financing, the PACE program seeks to secure a super-
priority first lien over all other lien holders on a property through a
governmental property tax lien. As the financing concept provides that
the lien, associated with the PACE loan, ``runs'' with the property,
this proves attractive to investors who provide PACE program funding.
With a super-priority lien position, the risk of investor loss becomes
very small as that lien has priority over pre-existing first mortgages
and has the possibility of continuing to run with the property to a
subsequent purchaser. This investor opportunity comes at the expense of
existing lien holders, who have not had the ability to consent or not
consent to the new lien and unexpectedly bear a new risk of loss that
did not exist at the time the mortgage was originated.
As a tax-related assessment, the PACE loan is fundamentally asset-
based lending that ``runs with the land.'' This means a purchaser of a
home with an existing PACE loan assumes the outstanding obligation and
any unpaid or delinquent amounts. Despite the benefit of highest
priority lien position, interest rates charged to borrowers for PACE
are typically substantially higher than for a first-lien mortgage.
Purchasers may not wish to acquire such obligations where the PACE
interest rate is higher than their purchase loan rate or the
improvements are out of date or in need of repair. State laws provide
for localities to collect administrative fees of up to 10 percent of
the loan amount usually added to the loan amount, and for lending
amounts tied not to borrower's ``ability to repay,'' but to the
property and its assessment up to 15 percent of the assessed value. The
holder of such a lien may move for foreclosure on the property or the
tax administrator may do so and recover the unpaid amount of the PACE
loan; other parties recover what remains.
Such loans are not recorded in local land records but in tax
records and may bear a denomination other than PACE such as an
abbreviated PACE program name. Such tax records usually list the amount
of the loan and the amount paid, but do not provide distinctions on
principal and interest. They are not part of ordinary mortgage record
searches.
Some PACE programs claim that PACE loans do not affect debt-to-
income (DTI) ratios, an important benchmark for consumers and lenders.
The Enterprises require lenders to include homeowner property tax
payments that would include PACE assessments as a component of the loan
applicant's present or future housing expense to calculate DTI for loan
eligibility. Unavailable data on DTI may permit a homeowner to incur
more debt with lenders unaware of the PACE obligation due to a lack of
DTI information or potentially inaccurate credit scores. Because PACE
loans are not recorded in land records but in tax rolls, often with
varying names or descriptions, they are difficult to identify in title
searches.
Finally, PACE programs lack uniformity and may differ in every
community within a state, making it challenging for lenders to evaluate
the implications for individual homeowners or home purchasers.
B. FHFA, Financial Regulators and Super-Priority Liens
In 2010, FHFA, the Office of the Comptroller of the Currency (OCC),
the National Credit Union Administration and the Federal Deposit
Insurance Corporation highlighted the risks attendant to PACE
lending.\1\ Fundamentally, the priming of a first mortgage was and
remains the central issue. FHFA directed Fannie Mae and Freddie Mac not
to purchase or re-finance mortgages with PACE liens and reserved other
potential actions. The Federal Home Loan Banks were alerted to the need
for vigilance in accepting collateral for advances that may have PACE
liens attached. FHFA determinations regarding residential PACE loan
programs have been upheld in three Circuit Court decisions.\2\
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\1\ For example, in OCC's Supervisory Guidance, OCC 2010-25
(July 6, 2010) at https://www.occ.gov/news-issuances/bulletins/2010/bulletin-2010-25.html, the OCC emphasized that beside loans, banks
investing in mortgage backed securities should take into account
PACE programs in their asset valuations and to consider the impact
of PACE programs on their institutions and the markets when making
any decision on ``associated bond underwriting.'' Overall, OCC
indicated it considered programs that failed to ``observe existing
lien preference'' to pose ``significant regulatory and safety and
soundness concerns.''
\2\ See County of Sonoma v. FHFA, 710 F.3d 987 (9th Cir. 2013);
Leon County v. FHFA, 700 F.3d 1273 (11th Cir. 2012); and Town of
Babylon v. FHFA, 699 F.3d 221 (2nd Cir. 2012) (appeal of
consolidated cases, after granting of motions to dismiss in the
Southern and Eastern Districts of New York).
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In 2014, FHFA re-stated its concerns regarding PACE and other
``lien-priming'' programs.\3\ In its public statement of December 22,
2014, FHFA summarized that--
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\3\ https://www.fhfa.gov/Media/PublicAffairs/Pages/Statement-of-the-Federal-Housing-Finance-Agency-on-Certain-Super-Priority-Liens.aspx.
The existence of these super-priority liens increases the risk
of losses to taxpayers. Fannie Mae and Freddie Mac, while operating
in conservatorship, currently support the housing finance market by
purchasing, guaranteeing, and securitizing single-family mortgages.
One of the bedrock principles in this process is that the mortgages
supported by Fannie Mae and Freddie Mac must remain in first-lien
position, meaning that they have first priority in receiving the
proceeds from selling a house in foreclosure. As a result, any lien
from a loan added after origination should not be able to jump in
line ahead of a Fannie Mae or Freddie Mac mortgage to collect the
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proceeds of the sale of a foreclosed property.
Enterprise programs support the ability of a borrower to purchase a
home and the Enterprise mortgage is recorded in first-lien position. A
PACE loan is only available to someone who owns a home. In the vast
majority of cases, home ownership is obtained by a mortgage loan in
which a lender has placed a substantial amount of capital at risk. For
the Enterprises, this means up to $510,400 or, in high cost areas, up
to $765,600 to provide homeownership opportunities. Accordingly, the
Enterprises require that the mortgage loans they purchase remain in a
first-lien position for the life of the loan.\4\ Also, the
congressional charters for the Enterprises require borrowers to have at
least 20 percent equity in a home or an approved form of credit
enhancement, such as mortgage insurance, to address the risk of
nonpayment. A municipality providing ``super-priority'' lien status for
a PACE loan can erode--partially or completely--that 20 percent equity
cushion, as required by statute, and place either the homeowner or a
regulated entity, or both, at substantial risk.
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\4\ Enterprise loans are packaged into mortgage backed
securities and purchased by investors which supports housing
finance; investors rely on the underlying loan pool in making their
purchases.
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PACE programs present a threat to the quality and stability of
large amounts of Enterprise loans. According to Fannie Mae and Freddie
Mac, in mid-2019 in California and Florida, the two most active
residential PACE jurisdictions, the Enterprises had over 5.4 million
loans with unpaid principal balances of approximately $1.18 trillion.
These bear a risk of impairment by super-priority PACE loans that the
Enterprises clearly stated in their loan instruments must be avoided.
Further, these loans, that ``run with the land,'' impair the
foreclosure process when that is an unavoidable outcome to the benefit
of PACE investors.
Consumer issues have surrounded the PACE programs from their
inception. These include the cost of funding, contractor sales
techniques (notably, responding to a limited homeowner
[[Page 2738]]
problem and marketing a full house retrofit), rolling the
administrative fees for the county into the PACE loan amount, product
sales at above market interest rates, workmanship issues, inadequate
disclosures and indiscriminate lending regardless of ability to
repay.\5\ Consumer protections at the state level for PACE lending are
uneven and in some instances non-existent. Multiple reports exist of
pressure on homeowners with PACE liens to pay off the PACE loans in
order to sell their homes, either to permit the purchaser to secure
financing or because the purchaser does not want to be saddled with a
loan with an interest rate that can be double the rate of a new
mortgage.\6\ Borrower demands for pay offs have occurred independent of
positions taken by FHFA.
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\5\ California enacted into law AB 1284 (California Financing
Law) in 2017. The California Department of Business Oversight
offered two opportunities for public input in November 30, 2017 and
April 19, 2018 regarding its rulemaking under the law for licensure,
program administration, consumer related provisions and cost benefit
analysis of its rules. See http://www.dbo.ca.gov/Licensees/PACE/.
Materials presented to the legislature and to the California
Department of Business Operations provide significant information of
consumer problems relating to PACE, including descriptions of
individual consumer issues with PACE administrators and their
contractors and with the impact on selling their homes. As well,
information on the effectiveness of individual products and how
quickly homeowners receive benefits in excess of the loan payments
(on higher cost loans) have been questioned and led to federal
legislation on disclosure requirements. Additionally, real estate
professionals have commented on the problems of selling homes with
PACE liens.
\6\ Id. Consumer advocacy groups have highlighted, along with
repeated newspaper reports, that this dilemma exists for homeowners
with PACE liens. Consumer complaints involving PACE loans on a range
of complaints have been detailed; see, for example, National
Consumer Law Center, Residential Property Assessed Clean Energy
Loans: The Perils of Easy Money for Clean Energy Improvements
(September 2017), pp. 5-17.
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Recognizing consumer issues, Congress in 2018 enacted amendments to
the Truth in Lending Act to require federal regulation when PACE loans
are made to assure more effective consumer protections, focused on
ability to repay requirements. The law did not mandate that such
properties impacted by such loans serve as collateral for mortgage
loans made, purchased or authorized by any primary or secondary market
participant. The Consumer Financial Protection Bureau was entrusted
with implementing this law by regulation.\7\
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\7\ Public Law 115-174 (2018), section 307; codified at 15
U.S.C. 1639c(b)(3)(C). Also, Bureau of Consumer Financial
Protection, Advance Notice of Proposed Rulemaking on Residential
Property Assessed Clean Energy Financing, 84 FR 8479 (March 8,
2019).
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C. Financing Energy Retrofitting
FHFA and other federal regulators support financing for residential
energy retrofitting, where appropriate, and, in many instances, that an
actual consumer benefit exists as documented by an energy saving
report. Such lending, by regulated financial institutions, is
undertaken with strict attention to ability to repay rules, safety and
soundness prescriptions and other elements of the robust range of
federal and state consumer protection provisions. Properly underwritten
loans provide sustainable interest rates, consider the financial
position of a homeowner and provide mortgage makers and mortgage
investors a reliable product for purchase. At the same time PACE
financing encumbers the foreclosure process with an obligation that
``runs with the land'' where normal foreclosure ends claims against the
property.
The Department of Housing and Urban Development (HUD) has taken
initial steps to address some of the same concerns described above. On
December 7, 2017, HUD issued a Mortgagee Letter announcing that the
Federal Housing Administration (FHA) will no longer insure new
mortgages on properties that include PACE assessments, citing concerns
about the potential for increased losses to the Mutual Mortgage
Insurance Fund (MMI Fund) due to the priority lien status given to such
assessments.\8\
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\8\ U.S. Dep't of Hous. and Urban Dev., Mortgagee Letter 2017-18
(Dec. 7, 2017).
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Despite restricting FHA insurance for properties already encumbered
by PACE assessments, nothing prevents a FHA-insured borrower from
acquiring a PACE loan in the future. HUD considers PACE assessments as
potentially dangerous to the MMI Fund and, further, placing these
assessments on FHA-insured properties post-endorsement creates a lack
of transparency making it difficult for the agency to understand the
true nature of the risks involved.\9\ HUD has indicated that it is
unknown how many existing FHA borrowers have taken out PACE loans and
has expressed concern that FHA is not in a first lien position.\10\
Allowing PACE assessments to essentially subordinate the FHA-insured
mortgage creates a default under the mortgage and is particularly
problematic for HUD and FHA as the MMI Fund is exposed to unmeasurable
risk.
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\9\ Press Release, U.S. Dep't of Hous. and Urban Dev., FHA to
Halt Insuring Mortgages on Homes with PACE Assessments (Dec. 7,
2017) https://archives.hud.gov/news/2017/pr17-111.cfm.
\10\ An Examination of the Federal Housing Administration and
Its Impact on Homeownership in America: Hearing Before the Subcomm.
on Hous., Cmty Dev., and Ins. Of the H. Comm. on Fin. Serv., 116th
Cong. (Dec. 5, 2019).
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D. Actions by the Federal Housing Finance Agency
The continuation of PACE programs and their adverse impact merits
review for potential modification by FHFA of its safety and soundness
and prudential standard directions to its regulated entities.
In its 2010 statement on PACE programs and in its directions to
Fannie Mae and Freddie Mac, FHFA indicated that the Enterprises could
undertake certain actions, including but not limited to, adjusting
loan-to-value ratios to reflect the maximum permissible PACE loan
amounts available to borrowers in jurisdictions with PACE program,
requiring in loan agreements that a PACE loan may only be made in
relation to an Enterprise purchased mortgage with the consent of the
Enterprise, tightening debt-to-income ratios to account for additional
borrower obligations associated with PACE loans and such other actions
as would be appropriate. The Federal Home Loan Banks were advised to
consider their acceptance of collateral that might be affected by PACE
loans as a prudent safety and soundness practice.
The most direct action taken was by the Enterprises issuing
bulletins and updates to their seller-servicer guides to indicate the
Enterprises would not make or refinance a mortgage loan for a property
encumbered by a PACE lien.\11\ This Request for Input asks for public
comment on enhancing the actions to be taken regarding PACE liens in
light of their continued threat to first lien mortgages and to
homeowners and home purchasers from the lien priming effects of PACE
loans.\12\ Such actions
[[Page 2739]]
are founded on FHFA's regulatory authorities relating to safety and
soundness and the prudential authorities enunciated in the Housing and
Economic Recovery Act of 2008.\13\
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\11\ Fannie Mae Selling Guide (May 1, 2019), Lender Letter
(September 18, 2009), and announcements (February 27, 2018; December
1, 2010; August 31, 2010): https://www.fanniemae.com/content/guide/selling/b5/3.4/01.html, https://www.fanniemae.com/content/announcement/ll0709.pdf, https://www.fanniemae.com/content/announcement/sel1802.pdf, https://www.fanniemae.com/content/announcement/sel1016.pdf, https://www.fanniemae.com/content/announcement/sel1012.pdf.
Freddie Mac Single-Family Seller/Servicer Guide (May 1, 2019),
Freddie Mac Single-Family Refinancing and Energy Retrofit Programs
page, Selling Guide Bulletin (August 24, 2016), Lender Letter
(August 20, 2014): https://guide.freddiemac.com/app/guide/section/4301.4, https://sf.freddiemac.com/general/refinancing-and-energy-retrofit-programs, https://guide.freddiemac.com/app/guide/bulletin/2016-16.
\12\ In certain related cases, focused mainly but not
exclusively on conservatorship authorities, courts have made clear
that both Enterprise guides and actions by FHFA regarding PACE are
appropriate and preemptive of state authorities, including state
taxing authorities. See e.g., Berezovsky v. Moniz, 869 F.3d 923 (9th
Cir. 201) (HOA priority liens); FHFA v. City of Chicago, 962
F.Supp.2d 1044 (N.D.Ill. 2013) (local regulation of property
maintenance preempted by FHFA action under HERA); and Commonwealth
of Mass. v. FHFA, 54 F.Supp.3d 94 (D.Mass. 2014) (even if
conservatorship not in place, court ruled that federal law preempts
state law that are in ``irreconcilable conflict'' with federal
statute and that applied to state housing statute at issue in case).
\13\ 12 U.S.C. 4513b provides FHFA should establish for its
regulated entities, by regulation or guidelines, standards related
inter alia to management of market risk and credit risk, management
of asset growth and such other operational and management standards
as the Director determines to be appropriate.
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FHFA, therefore, asks for public input on the following questions:
1. Should FHFA direct the Enterprises to decrease loan-to-value
ratios for all new loan purchases in states or in communities where
PACE loans are available? By how much should available loan-to-value
ratios be reduced to address the increased risk of such liens being
placed on the property and what related implications would result from
such actions? Should loan-to-value (LTV) ratios be reduced for all loan
purchases sufficient to take into account the maximum amount of a PACE
financing available in that community? Should potential future
increases in permitted percentage of available PACE financing-to-
assessed value be considered?
2. Should FHFA direct the Enterprises to increase their Loan Level
Price Adjustments (LLPAs) or require other credit enhancements for
mortgage loans or re-financings in communities with available PACE
financing? What increased levels would be appropriate for such LLPAs in
light of the risks of PACE financing posed to the Enterprises?
3. Should FHFA consider other actions regarding Enterprise purchase
or servicing requirements in jurisdictions with PACE programs?
4. Should FHFA establish safety and soundness standards for the
Federal Home Loan Banks to accept as eligible advance collateral
mortgage loans in communities where PACE loans are available? How might
those standards best address the increased risk of such collateral?
Should such standards be in line with actions that FHFA would undertake
for the Enterprises, recognizing the difference in business structures
between the Enterprises and the Banks?
5. How might the Enterprises best gather or receive information on
their existing guaranteed or owned mortgage loan portfolios to
understand which loans have PACE liens and in what amount? Should
mortgage loan servicers be required to gather and report such
information to the Enterprises on a periodic basis? What would the
costs and implications be of such a requirement?
6. Would it be most effective for states that authorize PACE
programs to require a registry of PACE lending so that information
currently only held by PACE vendors or local tax rolls could be
available and maintained on an ongoing basis? \14\ What data should be
included in such a registry? What access would be permitted while
protecting consumer privacy? Should a federal agency provide for such a
registry? What minimum information would be available to allow credit
reporting agencies to include PACE obligations in credit reports
obtained in connection with mortgage origination or servicing?
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\14\ California enacted in AB 2063, Section 13 (2018)
discretionary authority for the California Division of Business
Organizations to require establishment of a ``real-time registry or
data base system for tracking PACE assessments . . . [which may
include] features for providing or obtaining information about a
property's status with regard to PACE assessments placed on [a]
property, whether recorded or not.''
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7. Should servicers of mortgage loans for the Enterprises provide
an annual or more frequent notice to existing borrowers in PACE-
eligible communities informing them that, under the terms of their
mortgage, PACE liens are not permitted? Should borrowers be informed of
the difficulties that may arise in selling or refinancing their home
when a PACE lien has been placed on their property? What other
information, if any, should be provided by servicers to borrowers with
regard to PACE liens? Should borrowers in PACE jurisdictions be
required to execute any additional agreements or certifications in
connection with mortgages for the Enterprises, Home Loan Banks or FHA
guaranteeing the borrowers will not accept PACE financing for energy
efficiency improvements?
8. The Consumer Financial Protection Bureau published and received
comment on an Advanced Notice of Proposed Rulemaking on disclosures
under the Truth in Lending Act, as required by section 307 of the
Economic Growth, Regulatory Relief and Consumer Protection Act, Public
Law 115-174 (2018). The ANPR addresses, in line with the statute, TILA
sections relating to ability to repay requirements and to application
of civil money penalty provisions for TILA violations.
FHFA seeks input on matters beyond the scope of the statutory and
regulatory provisions addressed by the CFPB. For example, do consumers
face issues regarding the tax treatment of PACE loan payments and
reporting to consumers of deductible versus non-deductible expenses?
Are there consumer impacts from PACE liens on title searches? What
impacts might arise where local governments use structures such as an
unelected Joint Powers Authority that limit government responsibility
for PACE program administration? What options exist for a homeowner who
can no longer afford to repay a PACE lien, such as a tax deferral by
the taxing authority? What issues arise from the use of approved
contractor lists and the impact on costs, contractor regulation, and
recourse for consumers for defective equipment? What issues may arise
from notification practices regarding PACE liens at time of property
sales and other issues that align with or expand on consumer related
concerns raised by the CFPB?
9. What information regarding experiences under programs of the
Department of Housing and Urban Development relating to PACE may be
relevant for consideration by FHFA in its evaluation of public input?
Where PACE programs create super-priority liens, should loan products
issued or guaranteed by the government, such as Federal Housing
Administration mortgage insurance, consider adjustments such as risk
based mortgage insurance premiums or limits on partial or assignment
claims or the availability or terms of modifications allowable? Should
government programs, such as those of FHA, contemplate further limiting
the availability of mortgage insurance in PACE jurisdictions for
forwards, HECMS or both? Are there improvements that government
programs could undertake, such as FHA increasing utilization of its
``green'' insured mortgages or its Section 203(k) rehabilitation
mortgage insurance program to avoid the risks associated with PACE
programs?
E. Responses
FHFA invites responses on all aspects of this Request for input.
Respondents should identify by number the question each of their
comments addresses. Copies of all responses will be posted without
change, including any personal information you provide, such as your
name and address, email address, and telephone number, on the FHFA
website at https://www.fhfa.gov. Copies of all responses received will
be available for
[[Page 2740]]
examination by the public through the electronic docket for this Notice
also located on the FHFA website.
In responding to these questions, respondents should provide their
viewpoints as to the implications of such actions, the cost to business
or to the public of such actions, benefits or risks in such actions,
and specific terms or specific provisions that would be appropriate in
undertaking such actions. FHFA also welcomes additional input on any
issues raised in considering these questions or going beyond the
questions asked. Responders need not reply to all questions set forth
here. At the same time, respondents may suggest other actions that FHFA
should consider and provide an explanation of the rationale and
benefits of such action.
Dated: January 10, 2020.
Mark A. Calabria,
Director, Federal Housing Finance Agency.
[FR Doc. 2020-00655 Filed 1-15-20; 8:45 am]
BILLING CODE 8070-01-P
