This document provides a code of conduct for contractors participating in the Home Run Financing PACE program. It outlines ethical standards around truthful disclosures, fair treatment of customers, fraud prevention, and compliance with relevant laws. Specific guidelines address proper handling of PACE documents, nondiscrimination, protecting seniors from financial abuse, and ensuring project completion before payment. Contractors are instructed to treat customers honestly, make full disclosures, and not take advantage of people.

1. July 2022
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Home Run Financing
Contractor Training Program
Code of Conduct

2. Purpose of Curriculum
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At Home Run Financing we want to ensure that all sales reps follow the Code of
Conduct for PACE, and follow the classifications as set out by the
California Department of Financial Protection and Innovation
1 PACE programs and assessment contractors (or financing agreements)
2 PACE disclosures
3 Ethics
4 Fraud prevention
5 Senior financial abuse
6 Nondiscrimination
7 Consumer protection
There will be a multiple-choice quiz at the end of the Code of Conduct training

3. PACE Disclosures
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The Truth in Lending disclosures provide the property owner a great deal of
information about their PACE assessment, including, property owner and project
information, list of products proposed for installation, as well as the proposed
cost for installation of each, a Financing Summary that discloses Terms, Rate,
APR, Annual Installment Payment and Annual Administrative Fees. Disclosures
also include All “Upfront” Costs, Notice of Right to Cancel the Assessment
Contract or Financing Agreement, transferability, payments, and what happens
when they are late.
Code of Conduct
You will present customers with the full and complete set of PACE financing
documents which includes all pages of the Assessment Contract or Financing
Agreement, Right to Cancel, Application, Financing Summary, and all other Home
Run Financing documents, and instruct the customers to contact Home Run
Financing with any financing related questions.
You will not ask the customer to sign the Completion Certificate before the
construction is complete

4. Ethics
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While there are laws and statutes that seek to legislate ethical behavior, ethics
in the world of PACE funding really boils down to a few simple points.
Treat everyone equally, be honest, give full disclosure, and don’t take
advantage of people.
Code of Conduct
1 You must act in good faith to resolve promptly any complaint or grievance
that a customer may file with Home Run Financing or the Home
Improvement Contractor
2 You should seek always to provide high value products and services best
suited to a customer’s request of needs and comply with Eligible Product
requirements of Home Run Financing. Install only Eligible Products for
reasonable, market-based prices that are within industry price guidelines and
that do not exceed Home Run Financing maximum guidelines
3 You may not suggest or imply in any way that PACE is a government assistance
program

5. Ethics
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Code of Conduct
4 You may not suggest or imply that PACE is a free program
5 You will not ask the homeowner to lie to Home Run Financing in the
confirmation of terms (Welcome Call) or completion calls
6 You may not suggest or imply that PACE does not involve a financial obligation
that the homeowner must repay
7 You may not use check facsimiles to dramatize the amount of PACE Program
financing that would be available
8 You will not use a local government’s logo, city seal or other graphic in
marketing materials

6. Fraud Prevention
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Examples of contractor fraud targeted at consumers would be situations where a
contractor would misrepresent the quality of the products involved in an
improvement project, installing less than what was agreed to, or installing a
product or products of lower quality than agreed to with the homeowner. Fraud
also includes stacking assessments, which means writing multiple assessments
with different PACE programs in order to get around underwriting requirements.
Code of Conduct
1 You may not falsify credit application documents (such as proof of income) or
other documents
2 You cannot attempt to seek multiple assessments on a property for the
primary purpose of by-passing PACE legal limits
3 You shall not sign any financing related documents for any homeowner

7. Senior Financial Abuse
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Seniors are often deliberately targeted by scams, fraud, and misleading
marketing. One study found that while individuals over 50 comprised only 35%
of the American population, they accounted for 57% of all fraud victims. Senior
financial fraud can include encouraging senior homeowners to install products
that they don’t need or want, misleading them into thinking the project is part
of a required program, or taking advantage of their trust or inability to fully
comprehend the program or project.
Code of Conduct
1 You must protect all customers, especially those in protected classes such as
elders, from and against any exercise of undue influence that could lead to
adverse purchasing, pricing and financing decisions.
2 You must comply with all local, state and federal marketing and telemarketing
laws, regulations and rules, including but not limited to the Telephone
Consumer Protection Act, the Older Americans’ Act (including Elder Rights
Protection Principles) and the Truth in Lending Act

8. Nondiscrimination
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Discrimination based on age, race, color, religion, sex or sexual orientation,
ancestry, national origin, disability, familial status, marital status, or receipt of
public assistance is illegal. The Equal Credit Opportunity Act disclosure we
provide to applicants advises them that we are prohibited from treating people
differently. The concept of discriminating includes recommending PACE as a
financing option to one homeowner and not another, or charging more for a
product or project to one homeowner or another.
Code of Conduct
1 You may not charge different prices or use different PACE interest rates
depending on the race/religion/age/marital status/sex or sexual orientation of
the customer

9. Consumer Protection
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PACE legislation was passed in order to address selling agents taking advantage
of consumers
Code of Conduct
1 If you are indicating economic benefits to customers, you must always analyze
accurately each customer’s energy usage, and anticipated energy savings likely
to result from the Eligible Product installation following standards that can
withstand independent, third-party review and analysis
2 You may not provide, or even appear to provide, tax advice to customers
regarding any aspect of PACE financing. Home Run Financing may provide a
simple tool on its website that is merely intended to provide customers the
ability to easily quantify the effects if they determine that some or all of the
PACE funding payments are deductible. If asked about tax aspects of PACE
financing, you should urge customers to consult their tax advisor

10. Consumer Protection
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PACE legislation was passed in order to address selling agents taking advantage
of consumers
Code of Conduct
3 You may not begin work until the customers Right to Cancel period is over and
the contractor has received Notice to Proceed
In most cases the Right to Cancel period is 3 days, with an extension to 5
days for homeowners aged 65 and over in California, and everyone over 75
nationwide. Certain low-income homeowners may also qualify for an
extension to 5 days.
4 You can present the Certificate of Installation for signature to the customer
only after completion of the project and when the customer is satisfied and
ready for Home Run Financing to release funds to the Home Improvement
Contractor

11. Sarasota County, Florida
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Contractors providing PACE financing in Sarasota County, Florida should
additionally inform Eligible participants of the following:
Estimate of energy savings, insurance cost savings (if applicable) and return on
investment, including the range of efficiency options (if applicable) using industry
best practices;
Available rebates or incentives associated with Qualifying improvements;
If energy improvements are undertaken:
The benefits of installing energy efficiency improvements before renewable
energy to reduce costs overall;
The benefits of a full Energy Audit of their property, names of energy audit
professionals qualified through the Residential Energy Services Network ,
Building Performance Institute, Association of Energy Engineers, or other
comparable program, and any available incentive programs; and
Costs of the Energy Audit are eligible for financing as part of the assessment.