American buyers routinely tell us they expected French financing to be broadly similar to a US home loan, only in a different language. It is not. The two systems were built on different assumptions about risk, and the differences show up in pricing, paperwork and process.

For the buyer, the headline is favourable: euro borrowing is currently considerably cheaper than dollar borrowing. The 30-year fixed rate in the United States has been sitting around 6.6%, with the 15-year near 6%. Fixed rates for international buyers in France run broadly between 3.5% and 4.5%, and for US-based applicants typically in the upper part of that band. That spread is the single most compelling reason for an American to finance rather than wire the full purchase price.

Here is how the rest compares.

Credit scores don’t travel — and don’t matter

There is no FICO equivalent in France. No French bank will pull your score, and an 800 credit rating buys you nothing at the credit committee.

What French lenders assess instead is documented income stability and the ratio of your total debt service to your gross income. Regulatory guidance caps that ratio at 35%, insurance premium included, with limited discretion for lenders to go beyond it. Note that this is generally applied to all your existing debt — US mortgage payments, auto loans, student loans — without netting off the rental income those assets may generate. Americans with several financed investment properties are sometimes surprised by how much borrowing capacity that consumes.

Expect to supply three years of federal tax returns, W-2s or audited business accounts, recent pay stubs, bank and brokerage statements, and a schedule of existing liabilities. A US credit report is often requested as supporting evidence, but as context rather than as a score.

Fixed means fixed — and there is no 30-year

Both markets favour fixed rates, but for different reasons and over different horizons.

The US 30-year fixed is a product of a specific securitisation market. France does not have that market, and terms are shorter: 20 to 25 years is the practical maximum, with amortisation generally required to complete by age 75 or 80. Against that, French fixed rates run for the entire term with no reset, no ARM structure and no reversion.

The offsetting difference is prepayment. In the US, most conventional mortgages carry no prepayment penalty at all. France permits one, but caps it: the lesser of six months’ interest on the amount repaid. It can frequently be negotiated away at the outset, and it is waived entirely in certain circumstances including sale after professional relocation, involuntary job loss or death.

Loan-to-value and the FATCA factor

American buyers should plan for a deposit of 25% to 40% of the purchase price, with 60% to 75% loan-to-value the working assumption. Minimum loan sizes typically start around €250,000 to €300,000.

Then there is FATCA. US reporting obligations mean that only a subset of French banks actively lend to US citizens and green card holders. This is not a credit judgement; it is a compliance decision, and it varies bank by bank and desk by desk. The practical consequence is that the panel of lenders available to an American buyer is narrower than the panel available to a British or German one — which makes knowing who is genuinely open for business a significant advantage.

No escrow, no title insurance, no closing agent

The American closing apparatus does not exist in France, and the substitutes work differently.

There is no monthly escrow account collecting property tax and homeowners’ insurance alongside your payment. In France you receive and pay the taxe foncière — and, on a second home, the taxe d’habitation — directly, once a year. Budget for them separately.

There is no title insurance either, because the notaire’s role removes the need for it. The notaire is a public officer who verifies title, conducts the searches, drafts the deed and registers the sale. Their fees, together with transfer taxes, come to roughly 7% to 7.5% of the price on an existing property, depending on the department, and materially less on a new build. Americans should treat this as the equivalent of closing costs and budget accordingly.

Insurance you must have, and a signature you must wait for

Two French requirements have no US parallel.

The first is assurance emprunteur — life and disability cover assigned to the loan. In practice it is mandatory, it is priced on age and medical history, and it can be a meaningful monthly cost for older borrowers. You are entitled to source it independently rather than accept the bank’s group policy, and doing so often saves a considerable sum over the term.

The second is the statutory reflection period. Once a French lender issues a formal loan offer, you are legally prohibited from accepting it before the eleventh day, and the offer must remain open to you for thirty days. The wait is not negotiable and it is not a delay tactic — it is a consumer protection, and it should be built into your closing timetable rather than discovered at the last minute.

And the tax question

Financing a French property has consequences on both sides of the Atlantic — French wealth tax on real estate, rental income treatment under the régime réel, foreign tax credits, currency gain on debt repayment, and reporting obligations including FBAR and Form 8938.

Talk to BlueSky

Blue Sky Finance arranges French mortgages for US citizens and green card holders, and works with the lenders who remain genuinely active in this segment. We know how to present an American financial profile to a French credit committee, and we coordinate with your notaire and cross-border accountant throughout. Contact our team to discuss your purchase.