How can a PACE loan exit firm get more clients?

Property Assessed Clean Energy (PACE) financing pays for home improvements such as solar, roofing, HVAC and windows, and the homeowner repays it as an assessment on the property tax bill. Firms in this category help homeowners who cannot afford those payments, cannot refinance or sell because of the lien, or believe the financing was sold improperly. Demand is concentrated in a few states, the rules are specific, and the homeowners are often already in financial stress. Marketing has to be precise and honest.

Start with a warning about the search data. In the Strive analysis of Google Keyword Planner data from September 2025 to August 2026, the broadest term was “pace” (10,000 to 100,000 monthly searches), followed by “pace centers”, also in the 10,000 to 100,000 range¹. Many of those searches are not about financing at all. PACE is also the name of a Medicare and Medicaid program, the Program of All-inclusive Care for the Elderly², and terms such as “pace all inclusive care for the elderly” and “pace program for elderly” sit in the same national top list, each in the 1,000 to 10,000 range¹.

The financing terms are smaller: “pace loan” and “pace program” in the 1,000 to 10,000 range, with homeowners also searching for PACE administrators by name¹. Across 56 distinct national terms, the median top-of-page bid estimate (high range) was about $7.54, and about $14.65 for “pace loan”¹. These are bid estimates for a click, not cost per lead. Keyword Planner reports ranges, not counts.

Geography is narrow. State-level search data in this category is too thin or too irregular to quote a reliable state figure¹. The market history points the same way: the CFPB found residential PACE lending concentrated in California and Florida, with smaller activity in Missouri and an Ohio pilot⁶.

What this means: broad “pace” keywords waste money. Target financing-specific phrases, add negatives for elder care terms, and expect most good clients to come from partners who see the problem at a tax bill, an escrow analysis, a refinance or a sale.

The CFPB’s 2023 study of PACE loans made from July 2014 to June 2020 gives the clearest public numbers⁶:

The study also found that more than a third of PACE loans had APRs or fees high enough to meet Regulation Z’s high-cost mortgage definition, that a little more than 13% of borrowers received multiple PACE loans, and that more than 70% had a pre-existing mortgage⁶. For homeowners who pay taxes through escrow, the payment shock can be larger at first, because the servicer may add a cushion or collect a shortage⁶.

Those are the people who look for help: a tax bill that nearly doubled, an escrow payment that jumped, or a refinance that stalled at underwriting.

Firms earn money in different ways: flat fees for document review and a payoff plan, attorney fees on legal claims, or work as a licensed mortgage originator on the refinance that pays off the lien. Each model has its own rules, covered below. A referral fee from a lender for sending the refinance is not one of the options (see RESPA below).

Worked example: the homeowner’s refinance math and the firm’s lead value

Illustrative inputs except where cited.

Homeowner side. A PACE balance of $25,000 costs about $2,700 a year on the tax bill, about $225 a month⁶. If the homeowner qualifies to roll that balance into a 30-year mortgage at an illustrative 6.5%, the added mortgage payment is:

Monthly rate = 0.065 / 12 = 0.0054167. Payment = $25,000 × 0.0054167 / (1 − 1.0054167^−360) = $135.42 / 0.857 = about $158 a month.

That saves about $67 a month on paper, but it stretches the debt to 30 years, depends on the new mortgage rate and closing costs, and only works if the homeowner has the income and equity to qualify. Show the homeowner both numbers and the trade-off. Never call it guaranteed savings.

Firm side. Illustrative inputs:

• Flat fee per engagement: $1,500
• Inquiries that have a workable path (equity, income, or a legal claim worth review): 35%
• Workable inquiries that sign: 40%
• Gross margin: 60%

Inquiry to client rate: 0.35 × 0.40 = 14%. Gross profit per client: $1,500 × 0.60 = $900. Gross profit per inquiry: 0.14 × $900 = $126.

If you bid $14 a click on “pace loan” (near the $14.65 estimate¹) and 6% of clicks become inquiries, each inquiry costs about $233. That is nearly double what the inquiry is worth. Paid search works here only with tight financing-specific terms, strong negatives and a landing page that converts much better than 6%. Partner channels carry the business.

Mortgage and real estate partners

Lenders see PACE at the worst moment for the homeowner. Fannie Mae will not purchase a mortgage on a property with an outstanding PACE loan unless the PACE program does not give the lien priority over first mortgages¹⁴. Fannie Mae’s limited cash-out refinance rules make an exception that allows paying off a PACE loan or other debt used solely for energy-related improvements¹⁵. FHA said in 2017 that properties encumbered with PACE obligations are no longer eligible for FHA-insured forward mortgages, that PACE can be paid off through a rate and term refinance, and that cash-out refinances may still be used to pay it off¹⁶. A loan officer who knows you can explain these paths to a stuck borrower is a steady source of clients.

Florida requires the seller of a home with an unpaid PACE assessment to give the buyer a written disclosure at or before contract⁷. Agents in Florida see these files and need someone who can explain payoff timing quickly.

Legal aid and attorneys

Some homeowners have claims, not just a payment problem. California requires the program administrator to determine that the owner has a reasonable ability to pay before executing the contract, based on income, assets and debts, without counting home equity¹², and to hold a recorded oral confirmation of key terms before signing¹¹. Florida requires documented findings, including that total annual PACE payments not exceed 10% of household income, a written financing estimate, and a recorded call confirming the findings and disclosures⁷. When those steps were skipped, the homeowner may have a case. That is an attorney’s call, not a marketer’s.

Content and search

Write pages for the real questions: why the tax bill jumped, how escrow shortages work, whether a refinance can pay off PACE¹⁴¹⁵¹⁶, what the 2026 CFPB rule changed⁴, and what California and Florida law require⁷¹². Use “PACE financing” or “PACE loan” in titles, never just “PACE”, so you do not attract elder care searchers².

Direct mail

PACE liens are recorded, so mailing lists exist. Mail that looks official will draw complaints and may break state law (Florida bars PACE administrators and contractors from implying PACE is a government assistance program, and the same instinct should guide anyone marketing around PACE)⁸. Use your company name, say plainly that you are a private firm, and state your fees.

This is not legal advice. Talk to a consumer finance attorney in each state where you work.

The CFPB PACE rule (TILA and Regulation Z)

The CFPB issued its Residential PACE Financing rule on December 17, 2024. It was published in the Federal Register on January 10, 2025 and took effect March 1, 2026³. Key points⁴⁵:

• PACE financing is credit under TILA and Regulation Z. The tax-assessment exclusion now covers only involuntary assessments.
• Creditors must make a reasonable, good faith determination of ability to repay using the eight standard factors, verified with third-party records, and must consider escrow increases the PACE payment will cause.
• A PACE transaction is never a qualified mortgage.
• PACE companies that are substantially involved in the credit decision share the ability-to-repay duty and face TILA civil liability for failures. A company that only solicits applications or does administrative tasks is not substantially involved.
• High-cost mortgage (HOEPA) rules may apply, and the rule adds PACE versions of the Loan Estimate and Closing Disclosure.

For exit firms, the practical meaning is this: the rule governs PACE financing made from March 2026 on. The CFPB’s summary does not describe relief for assessments made earlier, so do not market the rule as a way out of an older PACE loan.

California

• A property owner may cancel a PACE assessment without cost until midnight of the third business day after the latest of signing, receiving the financing estimate, or receiving the right-to-cancel notice¹⁰.
• The program administrator must make a recorded oral confirmation of key terms before signing, including annual costs and the monthly amount to set aside¹¹.
• An ability-to-pay determination is required before the contract or the home improvement work begins¹².
• Anyone soliciting PACE contracts must be enrolled with a program administrator and licensed or registered with the Contractors State License Board (or exempt)¹³.

Florida

Florida rewrote its residential PACE law in 2024 (chapter 2024-273)⁷:

• Underwriting findings: no more than 20% of the property’s just value without mortgage holder consent, no negative amortization or balloon, current taxes and mortgage, and total annual PACE payments no more than 10% of household income⁷.
• A written financing estimate covering cost, annual payment, APR, prepayment rights, and a statement that a lender may require payoff at sale or refinance, plus a recorded phone call⁷.
• A three-business-day right to cancel⁷.
• No implying PACE is government assistance, free, or not repayable, and no kickbacks to contractors⁸.
• Agreements can be treated as unenforceable and removed from the property when the owner canceled in time, someone other than the owner obtained the financing, or funding was obtained through fraud in violation of the PACE statutes⁹.

Mortgage assistance relief and advance fees

Federal Regulation O covers services represented to help a consumer stop a foreclosure, modify a dwelling loan, or obtain forbearance, among others¹⁷. Covered providers may not collect a fee until the consumer signs a written agreement with the loan holder or servicer that includes the relief obtained¹⁸. Attorneys who provide the service as part of practicing law, are licensed in the right state and follow state rules are exempt from most of the rule, and from the fee ban if they deposit advance funds in a client trust account¹⁹. Whether a PACE assessment counts as a “dwelling loan” for this rule is a question for counsel, but if your marketing talks about foreclosure or tax sales, assume the rule may apply.

The Telemarketing Sales Rule’s debt relief provisions are defined around debts owed to unsecured creditors²⁰. A PACE assessment is a lien on the property, so that definition may not fit, but do not assume any advance-fee model is safe without a lawyer’s review.

RESPA and refinance referrals

RESPA Section 8 bars giving or accepting any fee, kickback or thing of value for referring settlement service business on a federally related mortgage loan²¹. A PACE exit firm that steers homeowners to a lender for the payoff refinance cannot take a referral fee for it. Earning money on the refinance generally means holding the required loan originator license and being paid for work actually performed; have a RESPA attorney confirm any arrangement before you rely on it.

Advertising claims

Do not promise removal, cancellation or savings. The FTC requires a reasonable basis for objective claims before ads run²³. Google requires financial services ads to show a physical address and all associated fees, and its loan modification policy disapproves ads that guarantee loan modification or foreclosure prevention or charge upfront fees unless a law firm provides the service²².

No public data gives a monthly curve for PACE exit inquiries. Predictable triggers:

• Tax bills. California’s annual secured property tax bill, which carries the PACE installment, is mailed by November 1¹¹. Expect calls in November and December.
• Escrow analyses. Servicers adjust escrow when they learn of a new PACE payment, which can create shortages and payment jumps⁶.
• Refinance waves. When mortgage rates fall, more owners hit the PACE lien at underwriting¹⁴¹⁶.
• Home sales. Florida’s seller disclosure⁷ and payoff demands at closing surface the lien.

• Bidding on “pace”. Much of that demand is the elder care program¹². Use financing-specific terms.
• Promising removal. Florida’s unenforceability grounds are specific and decided by facts and courts⁹. No firm controls the result.
• Selling the 2026 rule as a remedy. It governs new PACE credit, not old assessments³⁴.
• Taking lender referral fees. RESPA Section 8 bars them on federally related mortgage loans²¹.
• Charging before results. If Regulation O reaches your service, fees before the loan holder’s signed offer are banned unless the attorney exemption applies¹⁸¹⁹.
• Looking like the government. Official-looking mail invites complaints and echoes the misrepresentations Florida now bans in PACE sales⁸.

• The broad “pace” search is mostly an elder care program. Real PACE financing demand is concentrated in California and Florida.
• The CFPB found the average PACE loan added about $2,700 a year to tax bills and raised mortgage delinquency by 2.5 percentage points.
• The CFPB PACE rule took effect March 1, 2026 and applies ability-to-repay rules to new PACE credit. It is not a remedy for older assessments.
• Refinancing usually requires paying PACE off: Fannie Mae will not buy loans behind a priority PACE lien, and FHA stopped insuring forward mortgages on encumbered properties in 2017.
• Never promise removal or savings, avoid upfront-fee and referral-fee traps, and send legal claims to licensed attorneys.