On August 7, 2024, the Consumer Financial Protection Bureau
(CFPB) issued a report spotlighting four marketing and financing
practices relating to solar financing that it claims pose
significant consumer risks (the Report). The CFPB noted that
solar-powered electricity is a growing industry—suggesting
that these risks may become an enforcement priority. At the very
least, the CFPB stated that it will be working with state and
federal regulators to address these risks.
The Report identified several solar financing models, including
private loans, government-backed loans, leases, and power purchase
agreements. However, it focused primarily on the consumer risks
associated with private, solar-specific loans. Under the private,
solar-specific loan model, solar salespeople, solar installers, and
lenders often have agreements with each other to facilitate the
sale, installation, and financing of solar panels in just one
interaction with consumers. These loans typically
