60-second summary
If you are a Canadian who plans to finance a Florida purchase rather than pay cash, you have three realistic options. First, a cross-border mortgage from a Canadian bank's U.S. subsidiary (Desjardins Bank, Natbank, RBC Bank, BMO Bank, TD Bank N.A., CIBC Bank USA). These banks lend in U.S. dollars under U.S. regulation but recognize your Canadian credit, income and assets, which usually produces the lowest rate and the smallest down payment. Second, a Foreign National Loan from a U.S. private lender or non-QM mortgage broker. These programs do not require a U.S. credit score or a Social Security Number, but they typically require 25% to 35% down and carry a foreign national premium on the rate. Third, a cash purchase, often funded by re-mortgaging or drawing a HELOC on a Canadian property. According to the National Association of REALTORS®, 57% of Canadian buyers paid all-cash in the 12 months ending March 2025. The remaining 43% used U.S. financing of some kind. This guide explains how the loan paths actually work so you can decide which one fits your file.
Glossary
- Foreign National Loan: a U.S. mortgage program for borrowers who are neither U.S. citizens nor U.S. permanent residents and have no U.S. credit history. Underwriting relies on a foreign passport, a substantial down payment and alternative documentation of income and assets.
- Non-QM: non-Qualified Mortgage. A U.S. mortgage that does not meet the Consumer Financial Protection Bureau's "Qualified Mortgage" criteria. Foreign National Loans are typically Non-QM. They are legal but priced higher than agency loans.
- DSCR loan (Debt Service Coverage Ratio): a U.S. investor mortgage qualified on the rental cash flow of the property itself, not on the borrower's personal income. Common path for Canadians buying a rental property in Florida.
- LTV (Loan-to-Value): the loan amount divided by the property value. A 75% LTV means a 25% down payment.
- ITIN (Individual Taxpayer Identification Number): a U.S. tax ID issued by the IRS to people who are not eligible for an SSN. Some Foreign National Loan programs require it; many do not.
- SSN (Social Security Number): U.S. tax and identity number. Most Canadians who do not work in the U.S. will never have one.
- ARM (Adjustable Rate Mortgage): a U.S. mortgage with a fixed rate for an initial period (3, 5, 7 or 10 years), then floating. The dominant product for cross-border mortgages.
- PITI: Principal, Interest, Taxes and Insurance. The monthly carrying cost a U.S. lender uses to size the loan.
- Reg Z / TILA: Regulation Z and the Truth in Lending Act, the federal U.S. consumer protection framework that governs mortgage disclosure.
- OSFI: the Office of the Superintendent of Financial Institutions, the Canadian federal banking regulator. It does not govern U.S. lending.
- OCC: the U.S. Office of the Comptroller of the Currency, which charters and supervises National Associations (N.A.). Most U.S. subsidiaries of Canadian banks are OCC-chartered.
Why this topic exists for Canadians
Florida is the top U.S. destination for Canadian buyers. Florida Realtors data for the 12 months ending July 2025 puts Canadian dollar volume at 1.9 billion USD, a 52% jump over the prior year, with Canadians as the largest international buyer group in the state by dollar volume.[^1] At the U.S. national level for the 12 months ending March 2025, the National Association of REALTORS® reports that Canadians made up 14% of foreign buyers, with an average purchase price near 569,300 USD.[^2]
Most of those buyers paid cash. The same NAR data shows 57% of Canadian buyers closed without financing.[^2] The other 43% needed a U.S. mortgage, and that is where the friction starts. A Canadian without U.S. credit, U.S. income or a U.S. SSN does not fit the profile most U.S. lenders are built around. Two specialized lending tracks exist precisely to solve this gap: cross-border mortgages from Canadian banks' U.S. subsidiaries, and Foreign National Loans from U.S. private lenders. Both are legitimate. Both are governed by U.S. federal mortgage regulation (Reg Z, ECOA, RESPA) and Florida state consumer protection law. They differ on cost, on documentation, on who underwrites the file, and on what happens when something goes wrong.
Verified fact. Florida is the top U.S. destination for Canadian buyers, with Canadians representing 31% of all foreign buyers in Florida and 14% of foreign buyers nationally for the 12 months ending March 2025. Canadians paid all-cash in 57% of transactions and financed in 43%. Sources: Florida Realtors (2025) and NAR (2025).[^1][^2]
Path 1: Cross-border mortgage from a Canadian bank's U.S. subsidiary
This is the path most Canadian financing files should explore first. Several Canadian banks operate wholly-owned U.S. banking subsidiaries that are chartered in the United States, supervised by U.S. regulators (typically the OCC for National Associations and the FDIC for deposit insurance), and explicitly designed to lend to Canadians. The defining feature is recognition of your Canadian credit profile.
A standard Foreign National Loan ignores your Equifax Canada or TransUnion Canada file because the U.S. lender is not set up to read it. A cross-border mortgage from a Canadian bank's U.S. subsidiary does the opposite: your Canadian credit history, your Canadian income, your Canadian RRSP or non-registered investment balances, and in some cases your Canadian property equity, all enter the underwriting decision. The result is usually a lower down payment, a lower rate, and access to fixed or adjustable products that mirror the conventional U.S. agency market rather than the Non-QM market.
The main Canadian-bank U.S. subsidiaries active in Florida
The list below names the institutions, not specific products, since rates and program terms change. Use it to identify candidates, then call the U.S. subsidiary directly.
- Desjardins Bank, N.A. Wholly-owned U.S. subsidiary of Desjardins Group, headquartered in Hallandale Beach, Florida, and operating in Florida since 1992.[^3] Recognizes Canadian credit history. Maximum LTV stated by the bank is between 65% and 80% depending on county and state.[^4] French-language service available.
- Natbank. Wholly-owned U.S. subsidiary of National Bank of Canada, in Florida since 1994.[^5] Four branches, in Hollywood, Pompano Beach, Boynton Beach and Naples.[^6] Recognizes Canadian assets and Canadian credit history when underwriting.[^7] French and English service.
- RBC Bank (Georgia), N.A. Wholly-owned U.S. subsidiary of Royal Bank of Canada, headquartered in Raleigh, North Carolina, and serving roughly 500,000 Canadian clients across the U.S.[^8] Pre-approval is online and uses Canadian credit history; the bank advertises no bank or lender fees, no foreign national premium, and a 20% minimum down payment for primary or vacation properties.[^9] Operates in all 50 states by mail and online; no branch presence in Florida.
- BMO Bank, N.A. Wholly-owned U.S. subsidiary of Bank of Montreal, with a "Gateway Program" specifically for Canadians buying or refinancing in the U.S.[^10] Eligibility generally requires being an existing BMO customer for at least six months. Florida is on the eligible state list. Conventional fixed and adjustable products available.
- TD Bank, N.A. Wholly-owned U.S. subsidiary of The Toronto-Dominion Bank, with branches in 15 U.S. states and Washington D.C., including Florida.[^11] Cross-border banking and U.S. mortgages available to Canadian residents. TD's published guidance notes that a U.S. closing must be attended in person by the borrower or by a Power of Attorney executing in the U.S.[^11]
- CIBC Bank USA. Wholly-owned U.S. subsidiary of Canadian Imperial Bank of Commerce. Lends to Canadians using Canadian credit history. Application generally goes through a CIBC relationship manager rather than a website intake form.
Typical range. Canadian-bank U.S. subsidiary mortgages for Canadians in Florida commonly land in a 20% to 30% down-payment range for second homes, with adjustable terms of 3, 5, 7 or 10 years amortized over 30 years. This is a generalized practitioner observation. Confirm exact terms with the lender for your file.
Why this path is usually the best for Canadians
Three structural reasons make this path attractive. First, the underwriter actually understands a Canadian file, which means your file does not get repriced as "high risk" simply because there is no Equifax U.S. score. Second, you avoid the foreign national premium, a 1% to 2% surcharge on the loan amount that some Foreign National Loan programs apply to compensate for the perceived risk of lending to a non-resident.[^9] Third, you tend to land on conventional, agency-comparable products rather than Non-QM products, which means lower rates and cleaner secondary-market behaviour over the life of the loan.
Opinion. Among Canadian buyers who choose to finance, the cross-border mortgage from a Canadian-bank U.S. subsidiary is usually the cheapest path, and it should be the default first call. The Foreign National Loan path makes sense only when the cross-border path is unavailable for a structural reason: the property type is excluded (rare condotel, condo with low owner-occupancy ratio, vacant land), the borrower's documentation is non-standard (self-employed without two years of T1s, recent sale of a business), or the use case is investor cash flow only (DSCR-style underwriting on a pure rental).
Path 2: Foreign National Loan from a U.S. private lender
A Foreign National Loan is a U.S. mortgage product offered by private lenders, mortgage brokers and Non-QM wholesalers, designed for borrowers who do not have a U.S. credit file. It is governed by U.S. federal mortgage regulation (Reg Z, ECOA, RESPA, TRID disclosures) and by Florida state lender licensing under the Florida Office of Financial Regulation. It is legal, well-understood, and routinely closed for Canadian buyers. It is also more expensive than a cross-border mortgage, for reasons that make sense once you see how the underwriting works.
How underwriting actually works
A Foreign National Loan does not pull a U.S. credit score because there is none to pull. Instead, the lender substitutes three things. First, alternative credit references from the borrower's home country: a foreign credit report (Equifax Canada or TransUnion Canada), letters from Canadian banks confirming accounts in good standing, or evidence of mortgage and credit-card payment history in Canada. Second, alternative income documentation, typically two years of Canadian T1 personal tax returns and notices of assessment for an employed borrower, or 12 to 24 months of bank statements for a self-employed borrower. Third, verified liquid assets in a U.S. bank account, often three to six months of estimated PITI as reserves on top of the down payment.
For an investment property, the Foreign National Loan often morphs into a DSCR loan. The lender ignores personal income entirely and underwrites on a Debt Service Coverage Ratio of 1.0 or higher, meaning the property's gross rental income must cover the proposed PITIA at minimum.
Down payment, rate and term ranges
Down payments for Foreign National Loans commonly range from 25% to 35% of purchase price, with some programs requiring up to 40% for higher-risk property types (condotels, non-warrantable condos, very high loan amounts).[^12] Interest rates run a foreign national premium above the conventional rate, often quoted as 1% to 2% above the prevailing U.S. agency rate.[^9] Terms are usually 30-year amortizations with 3, 5, 7 or 10-year ARM resets, occasionally 30-year fixed but at a meaningful rate premium. Loan amounts can run from 100,000 USD on the small end to several million on jumbo programs.
Verified fact. The CFPB's foreign national underwriting guidance, and the published programs of major Florida non-QM lenders, place typical Foreign National Loan down payments in the 25% to 35% range with rates 1 to 2 percentage points above conventional U.S. agency rates. Property eligibility commonly excludes irrevocable trusts, land trusts and primary residences (most programs are second-home or investment-only).[^12][^13]
Use case: when the Foreign National path makes sense
Two scenarios push files into the Foreign National lane rather than the cross-border lane. The first is property type. Canadian-bank U.S. subsidiaries underwrite mostly to agency or near-agency standards. Condotels, non-warrantable condos with low owner-occupancy ratios, certain short-term-rental zoned properties, and 5+ unit multifamily properties may not be eligible for cross-border programs. Foreign National lenders, operating in the Non-QM market, will quote them. The second is the investor-only case where the buyer wants to qualify on the property's cash flow rather than on personal income. DSCR Foreign National Loans are purpose-built for that scenario and do not exist in the cross-border product line.
Acquisition mortgages compared: Canada, U.S. cross-border, U.S. Foreign National
The table below names jurisdictional levels explicitly so a reader can see where a given rule comes from. The "Canada" column references Quebec for provincial detail. Equivalents for Ontario, British Columbia and Alberta are forthcoming in dedicated guides.
| Aspect | Canadian mortgage (Federal CA + Provincial QC reference) | U.S. cross-border mortgage from Canadian-bank subsidiary (Federal US + State FL) | U.S. Foreign National Loan from private lender (Federal US + State FL) |
|---|---|---|---|
| Regulator | OSFI (federal), AMF (Quebec) | OCC (federal, for N.A. lenders), Florida OFR | CFPB (federal), Florida OFR (state licensure of lenders and brokers) |
| Underwriting input | Canadian credit (Equifax/TransUnion CA), Canadian T1s, OSFI stress test | Canadian credit, Canadian income, Canadian assets, plus U.S. property appraisal | Foreign credit references, foreign T1s or bank statements, U.S. property appraisal |
| U.S. credit score required | Not applicable | Generally no (Canadian file accepted) | No |
| SSN required | Not applicable | No (ITIN sometimes preferred but not required) | No |
| Typical minimum down payment | 5% to 20% depending on price and CMHC eligibility | 20% to 30% | 25% to 35% (up to 40%) |
| Foreign national premium | Not applicable | None | Typical, 1% to 2% of loan amount |
| Typical product | 5-year fixed or variable, 25-year amortization | 3, 5, 7 or 10-year ARM, 30-year amortization | 3, 5, 7 or 10-year ARM, 30-year amortization, occasional 30-year fixed |
| Renewal mechanic | Term ends, renew with same or new lender | At ARM reset, rate floats; loan does not need to be re-underwritten | At ARM reset, rate floats; loan does not need to be re-underwritten |
| Stress test | OSFI B-20 stress test applies | Internal lender ratios; no OSFI stress test | Internal lender ratios; no OSFI stress test |
| Property securing the loan | Property in Canada | Property in the U.S. (Florida) | Property in the U.S. (Florida) |
| Recording of the security | Land Register of Quebec (Registre foncier) for hypothec | Florida public records (county) for the mortgage | Florida public records (county) for the mortgage |
| Closing actor | Quebec notary | U.S. title company plus closing attorney (Florida is a title-company state) | Same |
The single most important conceptual gap to absorb: in Canada you sign a hypothec or mortgage at the notary or lawyer's office, on a 5-year term that you renew. In Florida you sign at a title company, on a 30-year amortization that you can keep for the full term, with the rate behaviour determined by whether you chose fixed or ARM at origination.
Numbers a Canadian buyer should run
Use the worked example below as a structure, not as a quote. Run your own numbers with the lender or a cross-border tax advisor.
Worked example: 600,000 USD condo in Hollywood, Florida
Assumptions: 600,000 USD purchase price. 25% down (150,000 USD). 450,000 USD loan amount. 30-year amortization. 6.5% rate (illustrative only, not a quote). Florida property tax around 1.1% of assessed value. HOA approximately 700 USD per month. Homeowner insurance approximately 3,500 USD per year (Florida is a high-cost insurance state).
Monthly cost breakdown (USD, 30-year amortization, 6.5% rate):
- Principal and interest: approximately 2,844 USD
- Property tax (1.1% of 600,000 USD divided by 12): 550 USD
- Homeowner insurance: 292 USD
- HOA: 700 USD
- Total monthly carry: approximately 4,386 USD
Up-front cash:
- Down payment: 150,000 USD
- Closing costs (financing case, Desjardins Bank guidance): 3% to 3.5% of purchase price, so 18,000 USD to 21,000 USD[^4]
- Reserves required by lender: typically three to six months of PITI, so roughly 13,000 USD to 26,000 USD held in U.S. account
- Total cash needed at closing: approximately 181,000 USD to 197,000 USD
Typical range. For a 600,000 USD Florida condo financed at 25% down, total cash at closing for a Canadian buyer commonly lands between 30% and 33% of purchase price, including down payment, closing costs and required lender reserves. This is a generalized estimate based on published lender ranges; exact figures depend on the specific lender, county and property.
Opinion. The number that catches Canadians off guard is rarely the down payment itself. It is the combination of Florida property insurance (high since 2022) and the lender's reserve requirement on a Foreign National Loan. Budget the full closing cash before you commit, not after.
Common mistakes Canadian buyers make on the financing side
The list below is enumerable, so it is presented as a list. Each item is a specific, observable trap, not a generic warning.
- Treating a U.S. ARM reset like a Canadian variable-rate mortgage. A Canadian variable-rate mortgage adjusts continuously with prime; the payment often stays fixed and amortization shifts. A U.S. ARM is fixed for a defined initial period (3, 5, 7 or 10 years) and then resets to a published index plus margin, with payments recalculated. Different mechanics, different risk.
- Calling a U.S. lender for "the rate" before getting pre-approved by a Canadian-bank U.S. subsidiary. The cross-border path is usually cheaper. Canadians who skip it pay the foreign national premium for no reason.
- Wiring funds from a Canadian account to a U.S. closing without a paper trail. The U.S. title company will require documentation of source of funds. Wire from a single source you can document, not from three commingled accounts.
- Believing the down payment is "the same" because the dollar amount looks similar. A 20% down on a Canadian primary residence under CMHC and a 25% to 35% down on a Florida second home are not the same product. Different LTV, different mortgage insurance treatment, different pricing.
- Not opening a U.S. bank account before applying. Lenders typically want to see the down payment "seasoned" in a U.S. account for 30 to 60 days, plus the reserves. Wiring money in two days before closing creates underwriting friction and sometimes blocks the file.
- Ignoring Florida's high homeowner insurance market. Premiums in Florida have increased materially since the 2022 hurricane season and the 2023 condo legislation. Old quotes are not reliable. Get a binder before going under contract.
- Closing costs estimated using Canadian benchmarks. Quebec welcome tax does not exist in Florida, but doc stamps, intangible tax, title insurance, lender title, recording fees and prepaid escrows do. Total Florida closing costs are commonly 3% to 4% of purchase price for a financed deal, not 1.5% as a Quebec buyer might expect.
- Choosing a Foreign National Loan when a DSCR loan would have qualified. For a pure rental-investment file, a DSCR loan can produce better LTV and rate. The two products are sometimes offered by the same broker and routinely confused.
- Forgetting flood insurance. A property in a Special Flood Hazard Area (FEMA Zone A or V) requires federal flood insurance. The lender will not close without it, and the cost is not trivial.
- Closing with a Canadian Power of Attorney. U.S. title companies generally do not accept POAs notarized in Canada by a Canadian notary. If you cannot attend the closing, the POA must be executed at a U.S. consulate or with a U.S. notary.[^11]
- Not coordinating with a Canadian advisor on T1135 reporting. A Canadian who acquires a Florida rental property at a cost above the T1135 threshold has Foreign Income Verification reporting obligations to the CRA. This is acquisition-side relevant because the borrower's Canadian tax planning depends on whether the Florida property is held personally, in a U.S. LLC, or in another structure.
Step-by-step: acquiring a Florida property with U.S. financing
The sequence below assumes you are going the cross-border route via a Canadian-bank U.S. subsidiary. Steps generalize to the Foreign National Loan path with minor adjustments to documentation.
- Open a U.S. dollar deposit account at a Canadian bank's U.S. subsidiary at least 60 days before closing. Move the down payment plus reserves into the account and keep statements.
- Obtain a written pre-approval from one or two cross-border lenders. Validity is typically 90 to 120 days.[^9] Use it to set your purchase budget realistically, not aspirationally.
- Work with a Florida-licensed real estate broker who has experience with Canadian buyers. Confirm the broker understands FAR/BAR contract mechanics and condo association approval timelines.
- Sign a Florida purchase contract (FAR/BAR or FAR-9) with a financing contingency, an appraisal contingency and an inspection period that fits the lender's timeline.
- Submit the full application to the lender within the financing contingency window. For a cross-border lender, expect 40 to 45 days to clear-to-close in routine files.[^9]
- Order home inspection, wind mitigation inspection (Florida-specific, reduces insurance cost) and four-point inspection if the property is older than 30 years.
- Bind homeowner insurance and, if applicable, flood insurance before the lender will issue a clear-to-close.
- Review the Closing Disclosure (CD) at least three business days before closing. Compare line-by-line to the original Loan Estimate (LE).
- Attend closing at the title company in person, or execute a Power of Attorney at a U.S. consulate or U.S. notary if you cannot attend.[^11]
- Wire the cash-to-close from your U.S. account, not from Canada, to avoid same-day FX and wire-rejection issues.
- Record the deed and mortgage at the county clerk's office. The title company handles this. Confirm recording within 5 to 10 business days post-closing.
- After closing, set up the property tax escrow (handled by the lender) and confirm with your Canadian advisor whether this acquisition triggers T1135 reporting in your next CRA filing.
FAQ
Is a Foreign National Loan the only option for a Canadian without U.S. credit?
No. The cross-border mortgage path through a Canadian-bank U.S. subsidiary is the more common and usually cheaper option for Canadians. The Foreign National Loan path exists for cases where the property type or borrower documentation does not fit a cross-border program.
Do I need an SSN or ITIN to get a U.S. mortgage?
No SSN is required on either path. An ITIN is sometimes required for the Foreign National Loan (program-dependent) and is generally required for U.S. tax filings if the property generates rental income. An ITIN is requested directly from the IRS using Form W-7.
Can I get a 30-year fixed-rate mortgage like an American buyer?
Sometimes, on a Foreign National Loan, with a meaningful rate premium. More commonly, both paths offer ARMs with 3, 5, 7 or 10-year initial fixed periods amortized over 30 years.
Will my Canadian credit score actually be recognized?
By a Canadian-bank U.S. subsidiary, yes, that is the entire point of the program. By a U.S. private Foreign National Loan lender, sometimes (foreign credit reports are accepted as alternative documentation), but the file is underwritten as a Non-QM file regardless.
Do I have to attend the closing in Florida?
Either you attend in person at the title company, or you execute a Power of Attorney with a U.S. consulate notary or U.S. notary. A Canadian notarial act is generally not accepted by U.S. title companies.[^11]
What happens at the ARM reset in 5 or 7 years?
The rate adjusts to the index plus the margin defined in the note. The loan continues; you do not have to "renew" the way a Canadian 5-year mortgage works. You can refinance at that point, or keep the loan, or pay it off.
Can I deduct the U.S. mortgage interest on my Canadian taxes?
Generally no. A non-resident U.S. property used as a personal second home does not generate Canadian-deductible interest. Rental properties may produce deductible interest against rental income on Form T776, but the rules are specific. Confirm with a cross-border tax advisor.
What if I want to buy through a U.S. LLC?
Possible on the Foreign National Loan side (some programs lend to LLCs, especially DSCR programs). Generally not on the cross-border path, where the borrower is a natural person. The decision to hold the property personally or through an LLC has cross-border tax and estate consequences and should not be made on the financing question alone.
Editorial team and essential disclaimer
Full disclaimer
This article is published for educational purposes only. It does not establish a professional advisory relationship between canadaflorida.com and the reader. The information reflects publicly available sources and practitioner observations as of the "Last reviewed" date in the frontmatter; it may become outdated as regulations, lender programs, rates, or market conditions change. Cross-border financing involves overlapping U.S. federal, Florida state, and Canadian federal and provincial rules. A guide cannot substitute for qualified professional advice in any of those jurisdictions. Before signing a mortgage application, a purchase contract, a closing disclosure, or any related document, consult a Florida-licensed mortgage banker or broker, a Florida real estate attorney, and a Canadian or cross-border tax advisor competent in your province. canadaflorida.com is not affiliated with any lender, bank, broker or third party referenced in this guide; references are provided as primary-source citations and not as endorsements. The publisher disclaims liability for losses or damages arising from reliance on this content. External links are provided for convenience and lead to third-party websites whose content is not controlled by canadaflorida.com. Jurisdictional rules differ across U.S. states and Canadian provinces; even within Florida, county-level rules (closing costs, doc stamps, recording fees) vary.