Compliance Alert: CFPB Publishes final rules on PACE transactions

The CFPB has published finalized rules on Residential Property Assessed Clean Energy (PACE) transactions.  The published rules and other resources can be found here. Several provisions in Regulation Z have been updated for transactions involving PACE transactions.  The main PACE rule provisions are:

• § 1026.2(a)(14), Definition of Credit
• § 1026.37 & .38, TILA-RESPA Integrated Disclosure Rule requirements
• § 1026.43(b), Ability-to-Repay/Qualified Mortgage Rule definitions
• § 1026.43(i), Ability-to-Repay for PACE transactions
• Appendix H to Part 1026—TILA-RESPA Integrated Disclosure model forms
• Supplement I to Part 1026 (including official interpretations for the above provision)

While Docutech does not currently intend on generically supporting PACE loans, Docutech seeks input on whether lenders are intending to offer PACE transactions.  If a lender is intending on offering PACE transactions, please reach out to Docutech’s Client Support at 1.800.497.3584.

The preceding is for informational purposes only and is not and may not be construed as legal advice. No third-party entity may rely upon anything contained herein when making legal and/or other determinations regarding its practices, and such third-party should consult with an attorney prior to embarking upon any specific course of action.