In ML 2017-18, FHA announced that it will no longer insure mortgages encumbered by Property Assessed Clean Energy (PACE) obligations due to their superior lien status. The December 7 letter is a reversal of the policies outlined in ML 2016-11, which allowed for, in certain circumstances, the continued payment obligation to PACE on foreclosed FHA-insured properties. The new guidance is effective 30 days after issuance of the letter.