Foreign National Mortgages & Property Financing Between the USA and Europe

Buying property across the Atlantic tends to raise the same set of questions long before any bank enters the picture. Most of what follows is written around those questions — the ones I actually hear from clients, in the order they usually come up.

Can Europeans get a mortgage in the United States?

The short answer is yes, and more often than most buyers expect. US citizenship, permanent residency and an established US credit history are not preconditions. A specific group of US lenders — alongside a smaller number of private banks with US desks — writes what the market calls foreign national mortgages, using alternative underwriting built around the borrower's real life rather than a domestic credit file.

In practice, the file rests on home-country tax returns from the last two to three years, current employment or business income documentation, statements for the material bank and investment accounts, and a clean source-of-funds narrative for the equity going in. An ITIN application replaces the missing social security number once the transaction moves forward.

The choice of lender matters far more than most buyers realise. Two banks looking at the same file can reach very different conclusions on pricing, leverage and required reserves. That is why the honest answer to "can I get a mortgage in the US?" almost always depends on the borrower in front of me, not on the passport they hold.

Can Americans get a mortgage to buy property in Europe?

Also yes — but Europe is not a single mortgage market, and the differences between countries are wider than most American buyers assume before they start looking. Spain, France, Portugal, Italy, Germany, Austria, Switzerland and Luxembourg each operate under their own rules for non-resident lending, and each has its own tolerance for US-source income and FATCA-related reporting.

Some banks in continental Europe are genuinely comfortable with US clients. Others quietly step back the moment they see a US tax residency, because the reporting workload outweighs the transaction for them. Local retail banks, international banks with a cross-border desk, and private banks all read the same file very differently. Treating "Europe" as one market is the single most common mistake I see on the US side.

For country-specific detail, the market pages cover the destinations most frequently on the shortlist: Mallorca, mainland Spain, France, Italy, Portugal, and Germany, Austria, Switzerland & Luxembourg.

How much can international buyers typically borrow?

Leverage is one of the first questions and, honestly, one of the least useful to answer with a single number. Ranges exist, but they are indicative — never a promise.

For Europeans purchasing residential property in the United States, loan-to-value on a foreign national mortgage usually sits between 55% and 70%. Investment property, higher price points and less conventional locations tend to push the required down payment upward. Portfolio-backed structures through a private bank can lift effective leverage further when meaningful assets are already under management on the European side.

For Americans buying in Europe, the picture is more varied. Non-resident LTV commonly lands somewhere between 50% and 70%, depending on the country, the property and the borrower. Spain and Portugal tend to be more open on non-resident files than, say, Switzerland. Private banks in Luxembourg, Switzerland or Monaco can go further, particularly when the transaction sits inside a broader wealth relationship.

What actually drives the outcome is the combination: residence, currency of income, property type, price relative to valuation, liquidity, wider assets, the specific lender, and whether the deal is a conventional mortgage or a private-bank-led structure. The right question is rarely "how much can I borrow?" but "how much should I borrow, and through which route?"

Does my passport matter, or is my country of residence more important?

Both, and neither in isolation. Lenders assess several factors that buyers often treat as one: nationality, country of residence, tax residence, where income is generated, and where assets are held. These are five separate questions, and different banks weight them differently.

A few real-world shapes help. A German citizen living and working in the United States is often a strong US file, even without a green card — the income is domestic even if the passport is not. A US citizen living in Lisbon is rarely a straightforward European file, because FATCA and US tax residency travel with the client. A British entrepreneur buying in Florida looks very different depending on whether the income is PAYE from a listed employer or distributions from a privately held company. An American receiving most of their income through a closely-held business will be underwritten quite differently from an American on a corporate salary.

Two files that look identical on the passport page can behave nothing alike at underwriting. That is why the first conversation is almost always a conversation about the whole picture, not the cover of the passport.

I have found a property. What should I do next?

Ideally, financing is mapped out before an offer is signed. That gives room to line up the right lender, agree indicative terms and understand what the equity and documentation actually need to look like. In reality, many buyers come to me after they have already found the property they want — and that is still workable.

A useful first pass covers four things: the property itself (location, type, price relative to valuation), the buyer profile (residence, income, assets, existing debt), a realistic financing level for that combination, and a short list of lenders that fit. From there, the work is preparing the documentation properly, coordinating with the notary, agent or attorney on the ground, and keeping the timeline aligned with the purchase contract.

If you have found a property and want a calm second view before committing, that is a good moment to get in touch. It is also a good moment to pause if the timeline is being rushed for reasons that have nothing to do with your interests.

Do I need to use a bank in the country where I am buying?

Not necessarily. A local mortgage secured against the property is one option, and often a good one — but it is not the only route, and not always the best structure once the whole picture is considered.

The alternatives worth comparing in parallel include international or private-bank financing (particularly relevant when there is already a banking relationship somewhere in Europe), portfolio-backed borrowing where an existing investment portfolio secures the purchase, and refinancing or equity release from a property you already own. Each has real trade-offs on rate, currency exposure, collateral, flexibility and tax treatment.

The lowest headline mortgage rate is a poor tiebreaker on its own. The right structure is the one that fits how your assets are actually arranged and what you want the exit to look like.

Can I buy through an LLC, company or holding structure?

For US purchases, a domestic LLC is common — and for good reason in many cases. For European purchases, holding structures vary widely by country: Spanish, French, Italian and Portuguese property each interact differently with civil, tax and inheritance law, and the "obvious" answer in one jurisdiction can be genuinely wrong in another.

Ownership structure affects lender availability (not every bank lends to SPVs, and those that do have their own documentation requirements), underwriting, tax and estate planning, the paperwork trail, and how simple or complicated the eventual exit becomes. Legal and tax advice belongs with the specialists in each jurisdiction — but the financing implications deserve to be on the table before the structure is finalised, not after. Deciding on ownership first and shopping for a mortgage second is often expensive to reverse.

What documents will lenders ask for?

The document list is less intimidating than it looks, and it varies with the profile. Broadly, lenders will want to see identification and proof of residence, the last two to three years of tax returns, current salary or business income documentation, company accounts where a business is involved, statements for the material bank and investment accounts, a clear picture of any existing liabilities, a documented source of funds for the equity, and information on the property being purchased.

The emphasis shifts with the borrower. Employed professionals lean on payslips and tax filings. Entrepreneurs lean on company accounts, distributions and a coherent narrative around the business. Retirees rely on pension income and asset statements. Primarily asset-backed borrowers — often the private-bank profile — rely more on the portfolio itself than on ongoing income. Preparing the file for the right lender is a large part of what makes an application go smoothly.

Will my documents need to be translated?

Usually less than buyers assume, and rarely on day one. Many European banks with international desks accept core documents in English, and several accept German or French directly. Formal certified translations are typically needed only for a subset of the file, and only once a specific lender has confirmed what they actually require.

Paying for a full sworn translation of every document before the lender is even chosen is a common and avoidable expense. Wait until the shortlist is agreed and the bank has been clear about what will be needed for final approval.

Can private banking or investment assets be used instead of a standard mortgage?

For clients with meaningful liquid assets, this is often the most interesting question on the page. Portfolio-backed financing — sometimes called Lombard lending — allows an investment portfolio to secure a loan used to complete a property purchase. It works in both directions: European assets can support a US purchase, and US or international assets can support a European purchase.

The upside is real: faster execution, no property lien in the traditional sense, generally competitive pricing, and flexibility on repayment. The trade-offs are real too. The pledged portfolio has to be maintained within agreed parameters, currency exposure needs to be understood (borrowing in EUR against a USD portfolio, or vice versa, is a genuine decision), and liquidity is now partially committed. Whether this route fits is not an investment recommendation — it is a structural conversation about how your balance sheet is arranged and what you want it to do.

Can I refinance after buying in cash?

In most cases, yes. Buyers who close in cash to secure a property — or because the timeline demanded it — often ask whether they can put financing in place afterwards. In both the US and most European markets this is realistic, subject to lender policy, seasoning periods and the specifics of the property.

The tools include post-purchase refinancing (drawing a mortgage against a property already owned outright), equity release from an existing property to fund the next acquisition, and replacing an existing mortgage with a structure that better fits the current picture. Timing matters: some lenders will refinance within months of a cash purchase, others require the property to be held for longer. The country, the lender and the borrower's wider position all shape what is actually available.

How does the advisory process work?

My role is straightforward. First, I take time to understand the buyer, the property and the jurisdictions involved — because the answer to almost every question above depends on that combination. From there I assess the realistic financing routes, identify lenders that genuinely fit the profile, and prepare the case so that it is presented clearly rather than as a raw file.

I then compare and negotiate the proposals that come back, and coordinate the financing through approval and closing alongside the notary, attorney or agent involved. I work independently and I use "I" throughout, because that is honest — this is a personal advisory practice, not a team behind a brand. Approval is never guaranteed in advance, but the file that goes in should be as strong as the underlying situation allows.