CMBS loan documentation must do more to protect structures from suffering a material increase in debt as a result of energy efficient upgrades, Moody’s Investors Service said in a report on Monday.

Specifically, the rating agency is concerned that loan docs today don’t do enough to prohibit borrowers from taking on Property Assessed Clean Energy (PACE) loans. PACE allows property owners to finance energy efficiency and water conservation projects through property tax assessments. The loans are typically senior to the first mortgages included in CMBS.

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