Support residential PACE by submitting your comment to the Federal Housing Finance Agency (FHFA) by September 13, 2012.
Court ordered Rulemaking by FHFA resulted in over 30,000 public comments in response to the FHFA’s Advance Notice of Proposed Rulemaking (ANPR), the overwhelming majority in support of PACE. The FHFA’s Notice of Proposed Rule (NPR):
- Allows Fannie Mae and Freddie Mac to bring default proceedings against homeowners with PACE assessments that are not paid off on demand,
- Prohibits Fannie Mae and Freddie Mac from consenting to a PACE assessment, and
- Directs Fannie Mae and Freddie Mac not to underwrite mortgages with PACE assessments.
Climate Protection Campaign is supporting PACENow’s, a nonprofit advocacy organization, position that the FHFA’s proposed rule is unnecessary and can not be justified, based on the evidence and record established with comments filed in response to the ANPR. Courts will decide whether the FHFA has acted arbitrarily or capriciously, in the light of that record. FHFA says it is considering three alternatives to its proposed rule. CPC encourages comment which rejects the FHFA’s proposed rule. We urge you to email to FHFA General Counsel Alfred M. Pollard. The email address is: RegComments@fhfa.gov. Please include “RIN 2590-AA53” in the subject line of the message. Below is a suggested draft that you can cut and paste into your message:
I support residential PACE programs and believe that they are an important tool for making homes more energy efficient and spreading the use of renewable energy through out the United States. PACE gives property owners new options on how to approach their home energy use. Therefore, I reject FHFA’s proposed rule and urge you to adopt a rule that would allow Fannie Mae and Freddie Mac to buy and hold mortgages with PACE assessments if they:
- Meet standards set forth in H.R. 2599 (The “PACE Assessment Protection Act of 2011 introduced in the U.S. House of Representatives in July, 2011) that satisfy FHFA concerns (FHFA’s Third Risk-Mitigation Alternative – H.R. 2599 Underwriting Standards – NPR Federal Register page 36108), or
- Are guaranteed by a qualified insurer or protected by a reserve fund (FHFA’s First Risk-Mitigation Alternative – Guarantee/Insurance – NPR Federal Register page 36107)
Thanks for your consideration
Please submit your comment by no later than September 13, 2012.
For more background and information please visit PACENow’s website.