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ARTICLE · 18 MARCH 2019

Keeping PACE With The Market: CFPB Seeks Information For PACE Financing For Possible Regulations

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On March 4, 2019, the Consumer Finance Protection Bureau ("CFPB" or "Bureau") issued an Advance Notice of Proposed Rulemaking seeking comments related to Property Assessed Clean Energy ("PACE")

United StatesFinance and Banking
J. Paul Forrester
J. Paul Forrester
Steven Kaplan
Steven Kaplan
Joy Tsai
Joy Tsai
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On March 4, 2019, the Consumer Finance Protection Bureau ("CFPB" or "Bureau") issued an Advance Notice of Proposed Rulemaking seeking comments related to Property Assessed Clean Energy ("PACE") financing.1 Specifically, the Bureau is contemplating regulations for PACE financing under the ability-to-repay ("ATR") requirements under section 129C(a) of the Truth in Lending Act ("TILA"), which are currently in place for residential mortgage loans, and is soliciting information to better understand the PACE financing market. The Bureau will consider such information in implementing section 307 of the Economic Growth, Regulatory Relief, and Consumer Protection Act ("EGRRCPA"), enacted in May 2018.  EGRRCPA amended TILA by directing the CFPB to prescribe regulations that account for the unique nature of PACE financing by (1) carrying out the purposes of TILA section 129C(a) and (2) applying TILA section 130 to violations under TILA section 129C(a) with respect to PACE

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