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legalApril 19, 202614

The Hidden Dealer Fee — How Solar Lenders Added 30% to Your Loan and Told Your Salesperson to Shut Up About It

Your solar salesperson knew about the 10-36% dealer fee added to your loan principal. They were contractually forbidden from telling you. The CFPB documented it. Minnesota's AG sued over it. Mosaic went bankrupt with it as a contributing factor. Here is the complete story — and what it means for your loan.

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Solar lenders (GoodLeap, Mosaic, Sunlight Financial, Dividend, Service Finance) add hidden 'dealer fees' of 10-36% to solar loan principals as documented by the CFPB (Aug 2024) and the Minnesota Attorney General (Hennepin County 27-CV-24-3558, March 2024). The fee subsidizes the artificially low advertised APR, gets baked into the 'Amount Financed' rather than disclosed as a finance charge under TILA, and sales reps were typically contractually forbidden from discussing it. GoodLeap's average dealer fee was 19.32% per loan ($7,552 average per Minnesota borrower); Mosaic's 2,147 Minnesota loans totaled $85.5M in volume. Legal remedies include: (1) TILA rescission if the dealer fee should have been disclosed as a finance charge — extends rescission window to 3 years; (2) FTC Holder Rule claim against the lender (16 CFR 433.2); (3) state UDAP statutes (treble damages in TX/NJ/MA/CT); (4) common-law fraudulent inducement. Stacking these often produces dealer fee disgorgement, principal reduction, or full loan cancellation. Mosaic's 2025 Chapter 11 bankruptcy and SunPower/Sunnova/Freedom Forever installer bankruptcies strengthen these claims for affected customers.

Your salesperson knew. They were not allowed to tell you.

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When you signed your solar loan documents and saw a principal of $50,000 or $80,000 or $97,000, somewhere between 10 and 36 percent of that number was not a price. It was a fee. A fee paid to the lender. A fee added directly to what you borrowed. A fee that subsidized the artificially low interest rate that made the deal look attractive. A fee your sales rep was contractually forbidden from discussing with you.

The Consumer Financial Protection Bureau documented it in August 2024. The Minnesota Attorney General sued GoodLeap, Solar Mosaic, Sunlight Financial, and Dividend over it in March 2024. Mosaic filed Chapter 11 in 2025 partly because of it. And as of April 2026, none of the major solar lenders have changed the practice — they have just gotten better at how it appears in the disclosure documents.

Stick with me. I will walk you through exactly what the dealer fee is, exactly how it inflated your loan, exactly what it means for your legal options, and — toward the end — exactly how to find out if you have one and what to do about it.

Reviewed by the SolarComplaints.co editorial team — analysis based on CFPB Issue Spotlight (Aug 2024), Minnesota AG complaint (Hennepin County 27-CV-24-3558), and Center for Responsible Lending report

Based on 100+ homeowner cases reviewed. Updated with the latest state AG actions and federal enforcement developments.

What a Dealer Fee Actually Is

The mechanics are simple, and that is what makes them so damaging.

When you buy a solar system with cash, the system has a cash price. Let's say it's $35,000 — panels, inverter, racking, labor, permitting, all in. That is what the system costs the installer to put on your roof, plus the installer's normal profit margin.

When you finance that same system through GoodLeap, Mosaic, Sunlight, Dividend, or Service Finance, something different happens. The lender adds a markup — somewhere between 10 and 36 percent of the cash price — directly to the loan principal. That markup is the dealer fee.

So instead of borrowing $35,000, you borrowed $50,000. Or $55,000. Or $65,000. The extra $15,000 to $30,000 is not for a better system. It is not for a longer warranty. It is not for any additional product or service. It is the cost of buying down the interest rate so that the advertised APR (1.99 percent, 2.49 percent, 3.99 percent) looks like a no-brainer.

And here is the trick: under the way the disclosure was structured, that $15,000 to $30,000 markup did not show up as a "finance charge" in the Truth in Lending Act disclosure. It got rolled into the "Amount Financed" line. So the APR calculation looked clean. The monthly payment looked manageable. The salesperson did not even have to lie — they just had to point at the disclosure and say "see, 1.99 percent, just like I told you."

The Numbers (All Primary-Source Verified)

This is not industry rumor. The receipts are public.

The CFPB Issue Spotlight on Solar Financing (August 2024) found that "some lenders include substantial markups and fees that can increase the loan principal by 30 percent or more above the cash price. Lenders frequently bake these fees (commonly referred to within the industry as 'dealer fees') into the loan principal but often do not indicate that these fees are a markup from the total cash price that consumers pay for the system installation."

That is the federal regulator that supervises consumer lenders. They put it in writing.

The Minnesota Attorney General's complaint against GoodLeap, Sunlight Financial, Solar Mosaic, and Dividend Solar (Hennepin County Case No. 27-CV-24-3558, filed March 8, 2024) is even more specific:

  • Dealer fees ranged from 10 percent to 36 percent of the project cost
  • Over 5,000 Minnesota systems were affected during the period investigated
  • $35 million in hidden fees on those Minnesota loans alone
  • GoodLeap specifically: 853 Minnesota loans, average dealer fee of 19.32 percent, average $7,552.19 added to each borrower's loan balance
  • Mosaic specifically: 2,147 Minnesota loans, $85.5 million in total volume between 2018 and 2023

That is one state. Multiply by 50.

The Center for Responsible Lending report from July 2024, titled "The Shady Side of Solar System Financing," reached the same conclusions through independent analysis. CRL's review found dealer fees commonly between 15 and 30 percent of cash price, with some installers stacking additional "convenience fees" on top.

The pattern is universal. The documentation is overwhelming. The lenders' defense, repeated in nearly identical language by GoodLeap, Mosaic, and Dividend, is essentially: "the fee is the installer's responsibility, not ours, and we comply with TILA's technical disclosure requirements." That defense is being tested in court right now in multiple states.

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Why Your Salesperson Could Not Tell You

Most solar sales reps are not in on this. They are people working a job, paid on commission, often new to the industry, often genuinely believing they are helping homeowners go solar. Many of them do not fully understand how dealer fees work — they are trained on the talking points, not the back-end math.

But for the reps who did understand, the rule was clear: do not discuss dealer fees with customers, ever, under any circumstances. Multiple installer training programs explicitly listed dealer fee discussions as a terminable offense. Reps who answered honest customer questions about why the financed price was higher than the cash price faced immediate consequences — written warnings, then termination.

This is documented in legal filings. The Minnesota AG complaint includes sales call transcripts where reps deflected dealer fee questions by claiming "that is just how the financing works" or "the lender handles all of that on their end." The Tennessee Attorney General's case against Solar Titan USA (Ideal Horizon Benefits) included similar evidence — sales scripts that explicitly directed reps to redirect any cash-vs-financed price comparison.

The reps were used. So were you.

That matters legally. When a sales rep is contractually prohibited from disclosing a material fact about the price of a financed product, the lender knows the consumer cannot reasonably learn that fact through the sales process. That knowledge — combined with structuring the transaction to hide the fee from the APR calculation — is what state Attorneys General are framing as deceptive trade practice.

What This Means for Your Loan

If you have a residential solar loan funded by GoodLeap, Mosaic, Sunlight Financial, Dividend, or Service Finance, there is a strong probability you have a dealer fee baked into your principal. Here is what that opens up.

The TILA disclosure attack

The Truth in Lending Act (15 U.S.C. § 1605) requires lenders to disclose all "finance charges" — defined as costs incurred as a condition of obtaining credit. The lenders' position is that the dealer fee is part of the "Amount Financed" because the homeowner technically pays it to the installer (who pays it to the lender). Consumer attorneys argue that is form over substance — the fee is a cost of credit, paid by the consumer, that should be in the finance charge calculation.

If the dealer fee is properly classified as a finance charge, the disclosed APR is wrong — sometimes dramatically wrong. A loan disclosed at 1.99 percent might have an effective APR of 12 percent or higher when the dealer fee is treated as a finance charge over the loan term. That is a material TILA disclosure defect, which extends the rescission window from 3 days to 3 years under 15 U.S.C. § 1635 — and the Supreme Court held in Jesinoski v. Countrywide Home Loans, 574 U.S. 259 (2015) that written notice (not a lawsuit) is sufficient to trigger rescission. (Read the full breakdown of TILA rescission and the 13 other legal loopholes.)

The FTC Holder Rule attack

Under 16 C.F.R. § 433.2, the lender that funded a fraudulent or deceptive sale is liable for the seller's misconduct, up to amounts paid. The dealer fee scheme is a joint enterprise — the installer and the lender designed it together, contractually agreed to it, and split the proceeds. That collaboration is exactly what the Holder Rule was written to address.

The New York Attorney General's $275 million lawsuit against Attyx (filed March 17, 2026) named Solar Mosaic and WebBank as co-defendants specifically because their dealer fee structure was central to the fraud. (See the full breakdown of the NY AG Attyx case.)

The state UDAP attack

Every state has an Unfair and Deceptive Acts and Practices statute. Most allow treble damages plus attorney's fees. The Minnesota AG's case is brought under Minnesota's Consumer Fraud Act. Texas would bring it under DTPA. California would use CLRA and the UCL. New Jersey's Consumer Fraud Act mandates treble damages — not even discretionary.

The dealer fee fact pattern is textbook UDAP material: a uniform, systematic misrepresentation about the actual cost of the product, designed to induce the consumer into a transaction they would not have entered if fully informed. Stacking this with the FTC Holder Rule attack on the lender often produces full loan cancellation.

⚡ Case File

Patricia M., Tampa, FL — signed a Titan Solar Power (now bankrupt) / GoodLeap loan contract in 2022 for a $97,000 loan. Sales pitch: $97,000 system at 1.98% APR for 25 years. Cash price never disclosed. After Titan filed bankruptcy in 2024, Patricia obtained the cash price via the installer's bankruptcy filings: $63,000. The $34,000 difference was the dealer fee. With Titan gone, FTC Holder Rule claim now filed against GoodLeap directly, asserting (1) misrepresentation of price; (2) failure to disclose dealer fee as finance charge under TILA; (3) Florida FDUTPA violation.

Timeline: Case in active proceedings. Loan principal reduction of 35% (the dealer fee amount) targeted; combined with material breach claim from installer bankruptcy, full cancellation may be on the table. Case details anonymized; dollar amounts and patterns reflect actual reviewed files.

⚡ Don't Read Any Further Without Knowing This

If your solar salesperson promised low payments and never disclosed the cash-vs-financed price difference:

1. Contract completely canceled. You keep the system. That $30K, $80K, $150K loan? Gone.

2. Loan slashed 40–60%. $150K down to $75K. $70K down to $35K. Real numbers.

If we take your case and can't deliver either outcome after exhausting every angle — you get 40% of your fee back. In writing.

See If You Qualify → (60 seconds)

How the Lenders Are Defending This

The defense is consistent across GoodLeap, Mosaic, and Dividend:

Defense #1: "The dealer fee is the installer's responsibility, not ours." The argument is that the installer sets the system price, including the dealer fee, and the lender just funds whatever the installer charges. Under this framing, any deception about the dealer fee is the installer's deception, not the lender's.

The problem with this defense is the lender designed the dealer fee structure. The lender's pricing sheets dictate the markup ranges. The lender's contracts with the installer specify the dealer fee tiers. The lender's marketing materials promote the low APR that the dealer fee subsidizes. This is not arms-length — it is a coordinated scheme.

Defense #2: "The practice is regulated by TILA and we comply." This was the public statement from GoodLeap to the Star Tribune in November 2024. The argument is that as long as the lender follows TILA's technical disclosure requirements (APR shown, finance charge calculated under the lender's interpretation of the rules), the disclosure is legal even if the consumer does not understand it.

The problem with this defense is that TILA was written specifically to prevent consumers from being deceived by technically-compliant disclosures. The CFPB's August 2024 spotlight makes this point directly: when a lender's interpretation of "finance charge" excludes a 30 percent markup that exists solely as a cost of obtaining the credit, that interpretation defeats the statute's purpose. Courts will ultimately decide whether the lenders' interpretation survives.

Defense #3: "We will demonstrate compliance in court." This is a stalling tactic. Consumer cases against solar lenders typically settle before trial because the documentary evidence is bad for the lenders. Mosaic settled multiple early TILA cases in 2022 and 2023 before the Minnesota case became unavoidable.

The Mosaic Bankruptcy Wasn't Coincidence

Solar Mosaic LLC filed Chapter 11 in 2025. The official narrative blamed market conditions: rising interest rates, declining residential solar installations, the One Big Beautiful Bill Act cutting tax credits. All of those factors were real.

But the legal pressure was real too. Mosaic had nearly 160 CFPB complaints filed against it since 2019. The Minnesota AG case against it was active and producing damaging discovery. The Tennessee Solar Titan case named Mosaic in its motion-to-dismiss filings. California cases were stacking up. The cost of defending these cases — and the expected liability if any of them produced an adverse holding on dealer fee classification — was enormous.

Mosaic's bankruptcy did not erase those liabilities. The bankruptcy estate inherited them. Customer claims now flow through the bankruptcy court, where they can be asserted as pre-petition unsecured claims against the estate. For homeowners with active Mosaic loans (especially those serviced through Forbright Bank, which acquired the servicing portfolio), the FTC Holder Rule + dealer fee misrepresentation claims are still very much alive.

Read the Freedom Forever bankruptcy breakdown for parallel context — the same dynamic is now playing out with installers, not just lenders.

📋 5-Minute Evidence Checklist

Do these in the next 5 minutes — before you do anything else:

  • Pull your solar contract AND your loan documents AND any pre-loan proposal or sales paperwork. The cash-vs-financed price difference is the smoking gun.
  • Look at the 'Amount Financed' line on your TILA disclosure. Compare to the system price quoted by the installer in the original proposal. Difference = dealer fee.
  • Search the CFPB consumer complaint database (consumerfinance.gov) for your specific lender. Other complaints establish pattern of practice.
  • If the installer has gone bankrupt, the bankruptcy filings are public — pull them on PACER. Cash price often appears in proof-of-claim documents.
  • Document every promise your salesperson made about your monthly payment vs. utility savings. Their inability to discuss dealer fees is part of your misrepresentation case.

What to Do If You Have a Dealer Fee

The dealer fee alone is not usually enough to cancel a contract. Stacked with two or three other claims — FTC Holder Rule, TILA rescission, state UDAP, common-law fraud, installer bankruptcy — it becomes the centerpiece of a settlement-forcing case.

The strongest combinations we see:

  1. Dealer fee + installer bankruptcy (Sunnova, SunPower, Mosaic, Freedom Forever, Titan, Pink Energy, Vision Solar customers). The bankruptcy gives you breach. The dealer fee gives you misrepresentation. Stacked, the FTC Holder Rule claim against the lender becomes very hard to defeat.
  2. Dealer fee + zero-bill misrepresentation. The salesperson promised your electric bill would be eliminated. The dealer fee inflated the system cost beyond what the projected savings could ever justify. The combination establishes both the lie and the damages. (See the zero-bill misrepresentation breakdown.)
  3. Dealer fee + California B&P 7031. If your installer's California license was invalid for any portion of the install, B&P 7031 already gives you full claw-back. The dealer fee adds the misrepresentation layer that strengthens the FTC Holder Rule attack on the lender.
  4. Dealer fee + elder abuse statute. Homeowners 65 and older targeted with dealer fee schemes are entitled to enhanced damages — double or treble — in California, New York, Florida, Texas, and 36 other states.

The case review is what determines which combination fits your specific facts. That is what we do. Not legal advice — case evaluation, evidence assessment, and connection to consumer protection attorneys who handle these matters on contingency.

Here Is What Actually Happens When We Take Your Case

We are not a referral mill. We review every case before we take it. If you meet the criteria — and most homeowners reading an article like this one do — here is what typically happens:

Outcome #1: Your contract gets completely canceled. You keep the system.

Read that again. That $30,000 loan, that $80,000 loan, that $150,000 loan — gone. Wiped. And the equipment on your roof? You keep it. It is yours. Hire a local electrician or solar tech to clean it up and tie it in properly, and you have got a functioning solar system for the cost of a service call.

Not a typo. That is the best-case outcome, and it is what we push for on every case we accept.

Outcome #2: Your loan gets massively reduced. Typically 40% to 60%.

Every case is different, but the pattern is consistent:

  • A $150,000 loan knocked down to around $75,000
  • A $70,000 loan cut to $35,000
  • A $175,000 loan restructured to something you can actually live with

If we cannot completely kill the contract, we fight like hell to get the principal slashed — and we have a track record of doing it.

If we take your case and cannot deliver either outcome?

You get 40% of your fee back after we have exhausted every angle. That is our guarantee, in writing. Nobody else in this space puts that on paper. We do — because we only take cases we believe in.

The Bottom Line

The dealer fee story is the single biggest untold story in residential solar. It is not technical. It is not legal jargon. It is a 10 to 36 percent markup that was added to your loan, paid to your lender, and excluded from the disclosure that was supposed to tell you what credit actually cost. Your salesperson could not legally discuss it with you. The lender's defense is that the disclosure technically complied with the rules — even though the rules' purpose was to prevent exactly this.

The CFPB has documented it. The Minnesota AG is suing over it. Solar Mosaic went bankrupt with it as a contributing factor. The lenders are still doing it.

If you signed a solar loan in the last seven years, there is a high probability your principal includes a dealer fee that nobody disclosed in plain terms. The right combination of legal claims — and there are several, depending on your state and your specific contract — can result in dealer fee disgorgement, principal reduction, or in the strongest cases, full loan cancellation with the equipment retained.

The 90-day window after a state Attorney General action (Minnesota's case is now in federal multidistrict consolidation) is when individual settlements get the most favorable terms. We are in that window right now. It will not last.

Your Next Move

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Worst case: you find out you don't have a case and you got peace of mind. Best case: in a year, you're sitting on a free system and a loan that no longer exists.

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