Financing options for a Canadian (and a Brit) in the US

Financing options for a Canadian (and a Brit) in the US

Investor · Calgary, Alberta · Member since 2016 · 168 posts · 123 votes

Hi, I am fairly new to BP and am considering investing in the US. I am quite familiar with financing options and rules in Canada, but the US is a totally different ball game. I'm still in the process of just starting out and researching different markets, but I would like to buy small multis (duplex/triplex/4 plex) for our first few investments. 

I'm wondering what options are out there for financing to foreigners - I am Canadian, my husband is British (and Canadian permanent resident). From what I've read, there's usually an extra 1-2% interest charge for conventional mortgages. What options are there for <20% down payment? What other options are out there that would be ideal for financing a rental that I may not be aware of? 

I've heard mortgages in the US take 45-60 days to process (!) Is it that long for everyone, or just non-Americans? How does that work? Is the property still only conditionally sold until the mortgage is fully processed, 2 months after you've put in an offer? Is it also true you have to be physically present in the title office on closing day? 

If a new corporation was to buy the property, how does financing work for that? Am I correct to assume that the corporation would still need to be backed by a personal guarantee? If the property is in a corporation's name, is it acceptable to have only one shareholder sign all the documents and be present on closing? 

Thank you for any answers and advice! 

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Thorold, Ontario · Member since 2017 · 22 posts · 4 votes
9y

@Brianne H.

Hi Brianne, this is copied and pasted from my post last week. hope it helps

Update on Banks

TD will finance a US Mortgage for Canadians

BMO Harris will Finance a U.S. mortgage for Canadians just not in NY (where i'm looking right now) or Texas.

RBC- Minimum $65,000 mortgage plus 40% down. Need to have 24 months reserve mortgage payments in bank

Hope this helps any Canadians

See this reply in the discussion

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  • Roy N.Pro Member
    Rental Property Investor · Fredericton, New Brunswick · Member since 2013 · 7k+ posts · 4k+ votes
    9y

    @Brianne H.

    Depending on where you plan to invest in the U.S.A., check with TD, BMO (Harris) or RBC banks who offer financing for Canadians though their U.S.A. subsidiaries.  You will be able to use your Canadian credit history and, possible, your existing bank relationship to {hopefully} obtain better terms than dealing directly with a U.S.A.-only lender.

  • Thorold, Ontario · Member since 2017 · 22 posts · 4 votes
    9y

    @Brianne H.

    Hi Brianne, this is copied and pasted from my post last week. hope it helps

    Update on Banks

    TD will finance a US Mortgage for Canadians

    BMO Harris will Finance a U.S. mortgage for Canadians just not in NY (where i'm looking right now) or Texas.

    RBC- Minimum $65,000 mortgage plus 40% down. Need to have 24 months reserve mortgage payments in bank

    Hope this helps any Canadians

  • Houston, TX · Member since 2017 · 4 posts · 0 votes
    9y

    Dear Brianne Hall,

    I am a Canadian investor as well and have been investing in the States for the last few years and also had problem obtaining loan as well. I have account with TD bank in Calgary and had approached them back in 2012 for a loan to buy properties in the US and was turned down. The bank mentioned they can't finance investment across the border. Per Roy N. recommend here, I might talk to them again to see if they had changed their policy. 

    I opened few LLC in Texas and Arizona to purchase my rental properties there and these LLCs did not help with my loan situation either. Despite they are US's identities (with their own tax number, EIN), its manager/member are still non residence Canadian. So far I closed my deals with cash and that is the only way I see how for Canadian (or at least for my case). I even asked Chase bank in Houston to give me loan using my properties in the State as collateral but got no where with that either.

    Depending on how you structure your LLC; one manager can sign the deals for the company regardless of how many members or managers you have in your LLC. That is how thing work for me.

    Hope this help.

  • Chris MasonPro Member
    Moderator
    Lender · CA · Member since 2015 · 9k+ posts · 10k+ votes
    9y

    Hi @Brianne H. and @Chau Pham,

    I pulled this yesterday for someone else, it might be of help. Disclaimer that I can't speak to the quality, service levels, or interest rate pricing, of anything there. It's just a list of lenders that put themselves out there as willing to work with foreign nationals. Time to dial for dollars!

  • Investor · Calgary, Alberta · Member since 2016 · 168 posts · 123 votes
    9y

    Thank you for the replies! The lenders list is very helpful, I will check into some of them. 

  • Thorold, Ontario · Member since 2017 · 22 posts · 4 votes
    9y

    @Chau Pham @Brianne H.

    You have to contact the banks US branch to get financing for US properties. Just make sure to use .com and not ,ca in your search.

    if you want to inbox me i can give you the numbers to call

    @Chau Pham

    i have not confirmed this yet but from other Canadians, i was told to not use LLC or LLP.

    CRA does not allow these as its now a company and you might have to pay double taxes. Was told to use LP and get lots of landlord insurance

  • Investor · Willow Spring, NC · Member since 2009 · 5k+ posts · 3k+ votes
    9y

    I am assuming you will stay in Canada. Most commercial banks don't like investors to be out of the area, so using RBC makes a lot of sense in places like NC where RBC Bank operates. By the way, using phrases like "...small multis (duplex/triplex/4 plex)..." doesn't fly well in the US where 1-4 family property is considered single family by almost all banks because of GSE designations. Commercial banks dump 1-4 family property to the residential side, then the residential turn to GSE underwriting, that leads to 'no' decisions. Better to call it as the bank sees it; as non-owner occupied, non-conforming, 1-4 family underwriting.  Saves everyone time.

    Related:  Non-US citizens can already borrow via US Government programs like the GSEs (e.g. Fannie Mae) as detailed on page 270 of the . See the section "Non–U.S. Citizen Borrower Eligibility Requirements" ... the question is if you intend to reside in the US or not.

    Fannie Mae purchases and securitizes mortgages made to non–U.S. citizens who are lawful permanent or non-permanent residents of the United States under the same terms that are available to U.S. citizens....

  • Investor · Calgary, Alberta · Member since 2016 · 168 posts · 123 votes
    9y
    Originally posted by @Chris Martin:

    By the way, using phrases like "...small multis (duplex/triplex/4 plex)..." doesn't fly well in the US where 1-4 family property is considered single family by almost all banks because of GSE designations. Commercial banks dump 1-4 family property to the residential side, then the residential turn to GSE underwriting, that leads to 'no' decisions. Better to call it as the bank sees it; as non-owner occupied, non-conforming, 1-4 family underwriting.  Saves everyone time.

    Good to know, I wasn't aware of 1-4 family still being considered single family. Seems a little odd that a 4 plex would be considered by most to be single family, but if that's the way they see it, I'll make sure to refer to it as such. 

  • Chris MasonPro Member
    Moderator
    Lender · CA · Member since 2015 · 9k+ posts · 10k+ votes
    9y
    Originally posted by @Brianne H.:
    Originally posted by @Chris Martin:

    By the way, using phrases like "...small multis (duplex/triplex/4 plex)..." doesn't fly well in the US where 1-4 family property is considered single family by almost all banks because of GSE designations. Commercial banks dump 1-4 family property to the residential side, then the residential turn to GSE underwriting, that leads to 'no' decisions. Better to call it as the bank sees it; as non-owner occupied, non-conforming, 1-4 family underwriting.  Saves everyone time.

    Good to know, I wasn't aware of 1-4 family still being considered single family. Seems a little odd that a 4 plex would be considered by most to be single family, but if that's the way they see it, I'll make sure to refer to it as such. 

     If a residential lender turns you away because you say "fourplex" instead of "single family fourplex," he's an idiot and you didn't want to do business with him anyways. :P

  • Investor · Willow Spring, NC · Member since 2009 · 5k+ posts · 3k+ votes
    9y

    LOL! It's the 'multi-family'(*) word that throws bank employees. It's like the acronym HELOC. Investors think they can get a HELOC for an investment property. There isn't a secondary market for seconds on NOO property. But the bank employee hears 'HELOC' and puts you in front of a banker versed in owner-occupied lending. That's the wrong dude. All starts with the vocabulary. I just suggest using the vocabulary that the people with the money have... meaning use phrases and words that the bank (and underwriters) use. Just a suggestion. Don't do it if you don't want, and just call people idiots when you can't get on the same page;)

    BTW, I went through this a few weeks ago. I walked in to Wells Fargo and asked for their contact person for Fannie Mae Multifamily originations. There are 25 FNMA MF originators in the country, and I knew that WF was one of them. The local branches don't get many people inquiring about such loans, so I wasn't surprised they couldn't find a contact in the 15 or so minutes I was there. I have the contact info for the Carolinas, just PM me if interested.

    (*) Note: "Multifamily housing is any rental housing having five or more dwelling units...", page 1 of the

  • Houston, TX · Member since 2017 · 4 posts · 0 votes
    9y

    Hello @Chris Mason, Thanks a million for the list. For sure I will check them out.

  • Houston, TX · Member since 2017 · 4 posts · 0 votes
    9y

    Dear @Chris Martin,

    Thanks for the Fannie Mae Selling Guide link. I was told also that if I can move to the US and apply for a Green card, I will be able to apply for loan like any other US citizen (perhaps through the US Government program liked you mentioned).  

    In the mean while I understand the options available to me are either:

    1) owner financed properties or

    2) Private lender with a much higher interest rate compared to banks

  • Houston, TX · Member since 2017 · 4 posts · 0 votes
    9y

    Dear @Allan Snow,

    Since I have been living oversea, I never thought about the double tax issue since I haven't deal with Canadian Revenue for quite a while now.  I should of double check with my accountant.  Thanks for the advice.

  • Rental Property Investor · Ventura, CA · Member since 2016 · 62 posts · 34 votes
    9y
    @ brianne hall I am British and moved to CA 8 years ago. The first home I closed on I had to fly back to the U.K. As my Mother was really sick at the time of closing. You have to get the documents signed in the presence of a US notary but you will be able to find one in Calgary near you. I had to pay to get every signature notarized and went to the foreign office to do it. It cost me about $450 extra to get this done but it was perfectly possible. We closed in 30 days so his wasn't an issue. Key for me was getting a mortgage broker who is willing to go the extra mile to help you and manage he time difference (included some calls at 1 am!). Do send me a message if you want the details of the lady who helped me. I was a permanent resident at the time of purchase and this made a difference in terms of getting a lender. I can't give you advice on lenders who work with foreign investors but I can tell you I have a broker in London that help me with my U.K. Rentals and finance and he specializes in this market space so finding an international mortgage broker is probably the key for you. Good luck and please send me a message if I can be of any help. Kate
  • Investor · Calgary, Alberta · Member since 2016 · 168 posts · 123 votes
    9y

    Thank you for the replies. I don't have any intention of moving to the US so would the correct term to use when looking for financing be non-owner occupied? 

    @Allan Snow is LP Limited Partnership? I haven't looked into this yet but do you have any more info on why an LLC might be double taxed by not an LP? Are we talking about Canadian or American LLCs?

    @Kate Stephens Good to know it can be done without being physically present if necessary! 

    So what about this 45-60 days to secure a mortgage that I've read in multiple places? How does that work? Is it only for foreigners or Americans as well? 

  • Roy N.Pro Member
    Rental Property Investor · Fredericton, New Brunswick · Member since 2013 · 7k+ posts · 4k+ votes
    9y

    @Brianne H.

    LLCs do not exist in Canada and are not {always|usually} recognized by the CRA in the same way as they are by the IRS in the U.S.A. - resulting in revenue being taxed in your hands.

  • Thorold, Ontario · Member since 2017 · 22 posts · 4 votes
    9y

    @Brianne H.

    This should help you and down near the bottom there is a post from Gord Stevenson which i will paste

    Home»Landlording and Rental Properties»What You Should Know About Investing in U.S. Properties From Abroad

    GORD STEVENSON on

    As the author said, Canadians need to be careful about double taxation. Traditional consensus was to stay away from using an LLC to hold US property because Canada would see the LLC as a corporation and the income as corporate income. Since the US sees LLC income as personal pass through income there is a mismatch so the Tax Treaty does not allow US tax paid to be recovered through a Foreign Tax Credit. So, double taxation. Traditionally, the consensus was to use an LLP instead because Canada does understand a partnership.

    However, the CRA (Canada's tax authority) changed their position on LLPs in about May 2016, starting with LLPs set up in Delaware and Florida, but this is likely to spread to other states as well. Now they say an LLP will be considered as a corporation as well. The CRA says that LPs will still be considered as partnerships but an LP (as opposed to an LLP) does not contain liability for the General Partner.

    So, going forward it seems that it may be better for Canadian Residents to hold US rental properties directly in the name of the inverstor(s) and reduce liability risk with increased liability insurance.

  • Thorold, Ontario · Member since 2017 · 22 posts · 4 votes
    9y

    @Brianne H.

    @Gord Stevenson has some pretty good info/ posts on the LLC and LLP LP for Canadians. check out some of his posts

  • Investor · Willow Spring, NC · Member since 2009 · 5k+ posts · 3k+ votes
    9y

    In the last 10 or so years, I only operate in LLCs. I'm in NC, though. The structure makes a lot of sense from my perspective. Not sure how pass through entities like an LLC "work" for Canadians... never had a Canadian as a member;)

    In my world... In a US LLC, members can 'carve out' their P/L/C percentages and there is a lot of flexibility depending on what members want. I'd give up all Income and Profit (the "P" in P/L/C) in favor of Capital for instance. It all depends on the LLC and the membership.

  • Rental Property Investor · Ventura, CA · Member since 2016 · 62 posts · 34 votes
    9y
    I don't know about Canada but I'm sure it is the same as Britain. The USA has taxation agreements with most countries it trades with so you don't pay tax in both countries. You have to pay tax in one country but you don't have to pay in both. There are accountants that specialize in this who can advise you.
  • Real Estate Broker · Wailea, HI · Member since 2016 · 134 posts · 77 votes
    9y

    If you are going to invest in vacation rentals in another market, my suggestion is to find a local lender who is familiar with that market. In Hawaii, that local knowledge can go a long ways towards getting financing for a VR or investment property that the big, mainland banks won't do.

  • Investor · Vancouver, British Columbia · Member since 2017 · 30 posts · 10 votes
    8y

    Hi @Brianne H.

    I was wondering if you found a lender that can work with you in US. I'm going through this process myself. I was down in Columbus and Cincinnati area last week, and have started to work with some realtors, but I'm having a really hard time finding lenders to work with me. 

    Thank you in advance, 

  • Investor · Calgary, Alberta · Member since 2016 · 168 posts · 123 votes
    8y

    Hi @Saeid Safarmehdi, I have not found a lender yet, but I also haven't been putting much effort into looking. Since I originally posted this, we had an unexpected change (in a good way) with our primary residence. We happened upon an opportunity to land our dream property much sooner and for cheaper than expected, so we're just in the process of finishing development and about to move in. Once it's done and we're refinanced it, I will then be looking much more seriously into US options. I am also considering Cincinnati, though I haven't made a trip out there yet - still working on preliminary research. Let's keep in touch, and maybe share some knowledge that we come across that's relevant to Canadians investing in the US! 

  • Robert EllisBusiness Member
    Developer · Miami, FL · Member since 2014 · 3k+ posts · 1k+ votes
    8y
    Originally posted by @Saeid Safarmehdi:

    Hi @Brianne H.

    I was wondering if you found a lender that can work with you in US. I'm going through this process myself. I was down in Columbus and Cincinnati area last week, and have started to work with some realtors, but I'm having a really hard time finding lenders to work with me. 

    Thank you in advance, 

     Hi Saeid, PM for some info on lenders that might be helpful.  

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