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FHFA PACE Rulemaking Strategy August 6, 2012

FHFA PACE Rulemaking Strategy August 6, 2012. Agenda. Overview of FHFA proposed rule Coalition Response Strategy: O utline of potential coalition response comments Grassroots strategy DOE/White House engagement Media strategy. FHFA Proposed Rule . Fannie Mae, Freddie Mac shall:

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FHFA PACE Rulemaking Strategy August 6, 2012

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  1. FHFA PACE Rulemaking StrategyAugust 6, 2012

  2. Agenda Overview of FHFA proposed rule Coalition Response Strategy: Outline of potential coalition response comments Grassroots strategy DOE/White House engagement Media strategy

  3. FHFA Proposed Rule Fannie Mae, Freddie Mac shall: Take actions necessary to preserve their right to make mortgages subject to PACE liens immediately due (including amending the Uniform Security Instruments). Not purchase any mortgage subject to a first-lien PACE obligation. Not consent to the imposition of a first-lien PACE obligation on any mortgage.

  4. FHFA’s Alternative # 1: Guarantee/Insurance Fannie Mae, Freddie Mac shall: Take actions necessary to preserve their right to make mortgages subject to PACE liens immediately due. Not purchase any mortgage subject to a first-lien PACE obligation or consent to a first-lien PACE obligation, except if: PACE lien is recorded; and Repayment in the event of foreclosure or similar default is irrevocably guaranteed by a qualified insurer; or Qualified insurer insures Fannie and Freddie against 100% of any net loss attributable to the PACE obligation in the event of foreclosure or similar default; or PACE program provides sufficient reserve fund for mortgage holders which would cover 100% of any net loss attributable to the PACE obligation in the event of foreclosure or similar default.

  5. FHFA’s Alternative # 2: FHFA’s Underwriting Standards Fannie Mae, Freddie Mac shall: Take actions necessary to preserve their right to make mortgages subject to PACE liens immediately due. Not purchase any mortgage subject to a first-lien PACE obligation or consent to a first-lien PACE obligation, except if: PACE obligation ≤ $25,000 or 10% of fair market value, whichever is lower; Loan-to-Value Ratio ≤ 65%; Debt-to-Income Ratio ≤ 35%; FICO ≥ 720; and PACE lien is recorded.

  6. FHFA’s Alternative # 3: H.R. 2599 Underwriting Standards Fannie Mae, Freddie Mac shall: Take actions necessary to preserve their right to make mortgages subject to PACE liens immediately due. Not purchase any mortgage subject to a first-lien PACE obligation or consent to a first-lien PACE obligation, except if: PACE lien is recorded; and H.R. 2599 underwriting standards are satisfied.

  7. PACE Proponents Proposed Response fundamentally disagree with FHFA’s position that PACE poses significant safety and soundness concerns; challenge the legal right of the FHFA to determine how and under what circumstances state and local governments can make valid special assessments that meet public purposes; Recommend adopting a REVISED Rule permitting Fannie & Freddie to purchase  and consent to mortgages with PACE liens if an appropriately constructed Alternative # 1 (insurance/loan loss reserve) or Alternative # 3 (H.R. 2599 standards) are satisfied; and, Provide additional evidence on the record supporting PACE and alternatives # 1 and # 3.

  8. Next Steps on Joint Comment Letter Email Ramona Willis (rwillis@wsgr.com) if your organization is tentatively interested in signing on to joint proponents comments by August 15th. If you are interested in contributing to the substance of the comments, gathering additional research and facts for the record, please contact Sheridan Pauker (spauker@wsgr.com) as soon as possible. Deadline for submitting comments: September 13th

  9. Coalition Coordination Weekly calls until comments are due? Grassroots strategy Action alerts (timing, and goal) Letter template (volunteers to draft this?) DOE/White House/Congress engagement Assignments for calls/visits Media strategy Media talking points Joint press release Op-eds

  10. Thank you for participating. Contact: Annie Lappéannie@votesolar.org

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