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Leagues Preparing CU Comments: CFPB’s Proposed PACE Rule

The California and Nevada Credit Union Leagues are preparing comments for the Consumer Financial Protection Bureau with respect to a proposed rule on Property Assessed Clean Energy (PACE) finance transactions.

The Leagues want to hear from credit unions on this issue. Please email Leagues Vice President of Regulatory Advocacy and Compliance Lisa Quaranta if you are interested in contributing.

You can view the Leagues’ executive summary here. It includes the following sections:

  • Background.
  • How PACE financing works.
  • California law.
  • Summary of proposed rule.
  • Key proposed definitions.
  • Proposed PACE ability-to-repay (ATR) provisions.
  • Proposed model disclosures.
  • Resources.
  • Questions to consider.

The bureau’s proposed PACE rule would:

  • Clarify PACE financing coverage under Truth in Lending Act (TILA) and Regulation Z through amendments to Regulation Z’s exclusion for tax assessments and tax liens from the definition of credit.
  • Prescribe ability-to-repay requirements for residential PACE financing.
  • Make other clarifications and amendments to certain provisions in Regulation Z to make clear how other rules in Regulation Z apply to PACE financing given its unique nature.

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