What to Do If Your Solar Loan Terms Differ From What You Were Promised

What should you do if your solar loan doesn’t match the pitch?

Put the Truth in Lending disclosure from your loan next to the salesperson’s proposal and list every difference in five terms: the APR, the finance charge, the amount financed, the total of payments and the payment schedule. Then send the lender a written dispute that names each gap and asks for your signed documents, keep paying while it answers, and file free complaints. Solar loan misrepresentation claims are built on that gap between the pitch and the paper, and if your loan carries the FTC Holder Rule notice, the lender can be answerable for the seller’s conduct up to the amount you have paid.

This page is about comparing what you were told with what you signed and acting on the difference. For a clause-by-clause tour of the agreement itself, see how to read a solar loan agreement.

What counts as solar loan misrepresentation?

Solar loan misrepresentation is a false or misleading statement about a loan’s cost or terms, made to get you to sign, that your signed documents contradict. The CFPB’s 2024 report describes the patterns behind it: prepayment terms that some consumers said were not clearly discussed when they signed, a “net system cost” after a presumed tax credit shown in a large font while the real loan amount sat in “a small, light font,” and dealer fees that lenders “typically” leave out of the cost of credit they present.

Some disappointments are not misrepresentation. A payment increase you were told about, utility rates that changed, or panels that underproduce in a cloudy year are real problems without being a gap between the pitch and the paper. What turns a disappointment into a claim is evidence of what you were told: the proposal, texts, emails, ads, and notes you made at the time.

How do you compare the Truth in Lending box with your proposal?

Regulation Z requires a lender to give closed-end loan disclosures “before consummation,” “in a form that the consumer may keep,” and “grouped together” and “segregated from everything else.” That is why they usually appear as a box. The finance charge and APR must be “more conspicuous than any other disclosure” except the lender’s name. Here is what each term means in the regulation’s words, and what to hold it against.

Term in the box	Regulation Z’s description	Compare it with
Annual percentage rate	”the cost of your credit as a yearly rate”	The rate in the proposal or the one the salesperson quoted
Finance charge	”the dollar amount the credit will cost you”	Any figure you were given for interest or fees, or the absence of one
Amount financed	”the amount of credit provided to you or on your behalf”	The system’s cash price, and any “net cost” in the proposal
Total of payments	”the amount you will have paid when you have made all scheduled payments”	The monthly payment you were quoted multiplied by the term
Payment schedule	”the number, amounts, and timing of payments scheduled to repay the obligation”	The single monthly payment you may have been shown

Three gaps are worth checking first. If the APR matches the pitch but the amount financed is higher than the cash price, a fee is likely inside the balance; our dealer fee guide shows how to size it. If the payment schedule lists a second, larger payment, the loan was built to reset. If the proposal’s “net cost” is smaller than the amount financed, the difference is likely a presumed tax credit subtracted from the loan, the practice the CFPB describes.

Small differences don’t count. When the amount financed is more than $1,000 and the loan is not secured by real property or a dwelling, Regulation Z treats the disclosed finance charge as accurate if it is within $10 of the correct figure. Also ask for the itemization of the amount financed, which shows amounts the lender paid to others on your behalf. The Truth in Lending Act describes it as something you can get “upon a written request.”

Why did the payment jump around the 18th or 19th month?

The CFPB found it “commonplace” for solar-specific loans “to re-amortize at a higher monthly payment amount at the 19th month of the loan term” unless the borrower makes a substantial prepayment, “frequently” 30 percent of the principal, matched to the tax credit. A 2024 CFPB consumer advisory said the payment “jumps higher after 18 months” unless you make a payment matching the projected credit, “whether or not you ultimately receive a tax credit.”

Read the schedule closely. If the box shows the higher payment, the disclosure may be accurate, and the dispute is about what the salesperson said. That distinction matters: Truth in Lending claims focus on wrong disclosures, while a salesperson’s misstatement is a question for state consumer protection law and, where it applies, the Holder Rule. One more date matters now. The IRS says the residential clean energy credit “is not available for any property placed in service after December 31, 2025,” so a loan built around that credit for a system installed in 2026 has no credit behind its prepayment. Our page on a solar loan payment that increased covers the clause in detail.

What remedies does the law give you?

The Truth in Lending Act. A lender that fails to make required disclosures is liable for actual damages, statutory damages of “twice the amount of any finance charge in connection with the transaction,” within limits the statute sets, and the costs of a successful action “together with a reasonable attorney’s fee.” For a loan like this, statutory damages are tied to specific core disclosures: the amount financed, finance charge, APR, total of payments, payment schedule and security interest. A suit generally must be filed “within one year from the date of the occurrence of the violation,” though a violation can be raised later as a defense if the lender sues to collect, unless state law provides otherwise. If your loan was sold, Truth in Lending claims against the buyer are generally limited to violations “apparent on the face of the disclosure statement.”

Rescission, in limited cases. The right to cancel a loan under the Truth in Lending Act applies when the lender takes a security interest in your principal dwelling, such as a mortgage, deed of trust, home equity loan or line of credit used for solar. The window is normally three business days, Saturdays included, and it can last up to three years if the required notice or material disclosures were not delivered. A typical solar-specific loan secured only by the panels usually does not carry this right, because the right turns on a security interest in the dwelling itself: Regulation Z’s definition of a security interest leaves out “incidental interests” such as interests in “fixtures,” and the 11th Circuit held in Lankhorst (2015) that a security interest in a fixture “does not give the party a security interest in the realty on which it is installed.” Check whether your loan is secured by the house.

The FTC Holder Rule. A seller may not accept the proceeds of a purchase-money consumer loan unless the loan contract includes a notice making any holder “SUBJECT TO ALL CLAIMS AND DEFENSES WHICH THE DEBTOR COULD ASSERT AGAINST THE SELLER.” The notice also caps what you can get from the holder on those claims: “RECOVERY HEREUNDER BY THE DEBTOR SHALL NOT EXCEED AMOUNTS PAID BY THE DEBTOR HEREUNDER.” The FTC said in 2022 that the rule “does not prevent state law from providing costs or attorneys’ fees against loan holders.” Look for the notice in your loan agreement.

State law. Deceptive practices and lending laws vary by state. Minnesota’s pending case against four solar lenders rests on state consumer protection and lending laws, and Michigan’s case against an installer and its lenders pairs the federal Consumer Financial Protection Act with Michigan’s consumer protection and home solicitation sales laws; both are allegations so far.

What should you send the lender in writing?

Write to the creditor named in your Truth in Lending disclosure and to the company that collects your payments, if different. Include:

1. Your name, property address and account number.
2. Each gap: what you were told, by whom, when, and where it appears (proposal page, text message, email), next to what the loan papers say.
3. What you want: a corrected disclosure, a refund or credit of a fee you were not told about, a payment schedule that matches what you were promised, or cancellation of the loan.
4. If your loan carries the Holder notice, a statement that you are asserting your claims and defenses against the seller under it.
5. Requests for a complete copy of the signed loan agreement and Truth in Lending disclosure, the written itemization of the amount financed, the electronic signature records for each document, your payment history, and the name and address of whoever holds the loan now.

Once you dispute the accuracy of information directly with a lender, the Fair Credit Reporting Act bars it from reporting that information to a credit bureau “without notice that such information is disputed by the consumer.” Send the letter by a method that proves delivery, copy the installer, keep a copy, and keep paying.

In what order should you act?

1. Check for an open cancellation window. If you signed in the last few days, cancel in writing now by the method your contract and state law require, and send a copy to the lender the same day. If your loan is secured by your home, Truth in Lending rescission may also apply. Windows vary by state and some exceed three days; use the deadline tool.

2. Identify the contract type and each company. Confirm whether you have a loan, lease, PPA or PACE financing, and write down the installer, the lender, the servicer and the warranty company, which may all differ.

3. Ask in writing, and complain for free. Send the letter above. For a system you bought, the FTC says: “If you have a problem with a system you bought, try to resolve it with the company first.” If that doesn’t settle it, the FTC directs you to ReportFraud.ftc.gov and your state attorney general. Treasury, the CFPB and the FTC “encourage consumers that believe they have been a victim of unfair or deceptive practices to file a complaint with CFPB, FTC, or their relevant state consumer protection office.” The CFPB takes solar loan complaints; its complaint page lists “Personal loans like installment, advance, and title loans” among the products it covers. Add your state contractor licensing board for the installer.

Disclosure: Candid Yak works with Titan Advocacy Group, a solar consumer advocacy firm, and may be paid when readers hire it.

4. If the lender refuses, get a free case review. When the lender’s written answer is no and your documents show a gap between the promise and the paper, an attorney-backed firm that offers a free case review can measure the gap against your state’s law and the remedies above. Before you sign with any firm, make sure it has read your loan papers, tells you whether a free step is still open, names the attorney licensed in your state on your file, gives you its fee and what happens to the fee if the lender refuses in writing before you pay, never tells you to stop paying, and promises no result and no link to your lender or installer.

5. Other routes. Paying off or refinancing the loan can end the reset or lower the rate, though a dealer fee already in the balance comes along; compare consolidation loans before deciding.

Disclosure: Candid Yak works with Titan Advocacy Group, a solar consumer advocacy firm, and may be paid when readers hire it. This page’s author, Kira Fairbank, is a manager at Vacation Ownership Consultants, a timeshare exit firm.

This is general information, not legal advice. Which remedy fits turns on how your loan is secured, the dates in your documents and your state’s law, and the Truth in Lending deadlines are short, so put your loan papers and the proposal in front of an attorney licensed in your state before you send a notice, sign a release, or change any payment.