For family offices and ultra-high-net-worth borrowers, property portfolios are rarely confined to a single jurisdiction. Prime residential assets in London, Paris, Monaco, Geneva, and the South of France are often held simultaneously, reflecting diversification strategies, lifestyle considerations, and long-term capital preservation.
As these portfolios mature, the question of how to unlock liquidity across borders becomes increasingly important. Rather than borrowing asset by asset, many families now explore consolidated facilities secured against multiple properties across multiple countries.
From a borrower’s perspective, the logic is compelling. From a lender’s perspective, however, underwriting multi-property, multi-country collateral packages is one of the most complex exercises in private credit. Approval is not driven by headline asset value alone, but by how risk behaves across jurisdictions, legal systems, currencies, and ownership structures.
Willow Private Finance works closely with private banks and specialist lenders to structure and present these collateral packages in a way that aligns with lender underwriting frameworks while preserving flexibility, discretion, and long-term strategy for family offices.
Several forces are accelerating demand for cross-border collateralised lending. First, prime property values remain historically high, meaning significant equity is embedded within long-held assets. Second, investment opportunities—particularly in private markets—require rapid, flexible access to capital.
At the same time, lenders have become more sophisticated. Advances in risk modelling, legal coordination, and international enforcement have made it possible to underwrite multi-country collateral where this would have been impractical a decade ago.
That said, lender appetite remains selective. Only well-structured portfolios, supported by professional governance and conservative leverage, are suitable for cross-border collateralisation.
Lenders do not view a multi-country collateral package as a collection of independent properties. They assess it as a single risk system.
The first question is correlation. Assets located in different countries may appear diversified, but lenders examine whether those markets behave independently under stress. Political stability, buyer nationality, currency exposure, and capital controls all influence how correlated assets truly are.
The second question is enforceability. A lender’s willingness to rely on collateral depends on how confidently security can be enforced across jurisdictions. Reliable legal systems with predictable outcomes are favoured over complexity, regardless of headline value.
Finally, lenders consider operational risk. Managing security across borders requires coordination, cost, and time. These factors influence leverage limits, pricing, and structure.
Legal enforceability is often the defining factor in cross-border underwriting. Lenders assess each jurisdiction individually before considering how they interact collectively.
Key considerations include mortgage registration processes, creditor rights, insolvency regimes, and the practical realities of enforcement. Jurisdictions with transparent land registries and established lender protections are viewed more favourably.
Where properties are held via offshore companies or trusts, lenders also require legal opinions confirming that security can be taken and enforced without restriction. Any ambiguity materially reduces appetite.
As a result, not all properties within a portfolio contribute equally to borrowing power. Some assets may be discounted, capped, or excluded entirely from collateral calculations.
Valuation becomes more complex when assets sit in different markets. Lenders rarely rely on a single valuation methodology.
Each property is valued independently, often by jurisdiction-specific specialists, before internal haircuts are applied. These haircuts reflect liquidity, transaction depth, and market volatility rather than current price alone.
Importantly, lenders focus on downside value, not peak value. In thin ultra-prime markets, this can result in conservative assumptions even for exceptional properties.
The combined collateral value is therefore not a simple aggregate of market prices. It is a risk-weighted figure designed to withstand stress scenarios.
Leverage is deliberately restrained. In 2025, blended loan-to-value ratios for multi-country collateral packages typically range between 30% and 50%, depending on jurisdiction mix and asset quality.
Lower leverage compensates for complexity. It allows lenders to tolerate legal friction, currency volatility, and longer enforcement timelines without increasing credit risk.
Family offices often choose to borrow below lender maximums to preserve flexibility, reduce covenant pressure, and support long-term refinancing options across multiple markets.
Where assets and liabilities span different currencies, lenders conduct detailed stress testing. They assess the impact of adverse FX movements on both collateral coverage and debt servicing.
Facilities may be denominated in a single base currency or split across tranches to align with asset locations. Hedging strategies are sometimes required, particularly where currency mismatches are material.
Currency risk is not viewed in isolation. It is assessed alongside liquidity planning, income sources, and overall balance-sheet resilience.
In cross-border underwriting, borrower quality is as important as collateral quality. Lenders favour family offices with clear governance, professional advisors, and documented decision-making authority.
Credit committees expect clarity on who controls assets, who authorises borrowing, and how disputes are resolved. Informal or fragmented governance structures introduce unacceptable uncertainty at this level of lending.
Facilities aligned with long-term strategy—such as liquidity management or investment deployment—are viewed more favourably than opportunistic borrowing requests.
Private banks are often cautious with multi-country collateral, particularly where assets sit outside their core jurisdictions. They may require asset consolidation, conservative leverage, or additional guarantees.
Specialist lenders are frequently more flexible. They are accustomed to complex collateral packages and are often willing to underwrite assets across multiple countries, provided legal enforceability is clear.
In many cases, optimal outcomes involve a hybrid approach—using specialist lenders for cross-border collateral while maintaining private banking relationships for liquidity and wealth management.
Willow Private Finance structures across both channels, ensuring the solution fits the strategy rather than the institution.
One common mistake is assuming that geographic diversification automatically improves borrowing terms. If jurisdictions behave similarly under stress, diversification offers little benefit from a lender’s perspective.
Another pitfall is poor sequencing. Attempting to engage lenders before aligning legal structures, valuations, and governance often leads to delays or rejections.
Finally, underestimating the time required for cross-border execution remains a recurring issue. These facilities require patience, coordination, and experienced oversight.
Willow Private Finance specialises in complex, multi-jurisdiction property finance for family offices and UHNW clients. We approach cross-border collateral as a strategic exercise, not a transactional one.
We work closely with lenders, lawyers, and tax advisors to ensure collateral packages are robust, enforceable, and aligned with long-term objectives. Our focus is on conservative leverage, clear narrative, and durable structures that remain viable across market cycles.
In 2025 and beyond, multi-property, multi-country collateral packages will remain a powerful tool for sophisticated borrowers—but only when structured intelligently.
For family offices, success lies not in maximising leverage, but in aligning property wealth with liquidity, governance, and long-term strategy. Lenders will continue to support these structures where discipline, transparency, and professional advice are evident.
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About the Author
Wesley Ranger is the Director of Willow Private Finance and has over 20 years of experience advising family offices and ultra-high-net-worth individuals on complex property finance. He specialises in multi-property and cross-border collateral structures, working closely with private banks and specialist lenders to deliver robust, strategically aligned financing solutions across jurisdictions.
Important Notice
This article is for general information purposes only and does not constitute personal financial, legal, or tax advice. Cross-border lending involves complex legal, regulatory, and currency considerations that vary by jurisdiction and circumstance.
Lending availability, eligibility, and terms may change at any time and are subject to lender criteria. Independent legal and tax advice should always be obtained before entering into any financial arrangement.
Willow Private Finance Ltd is authorised and regulated by the Financial Conduct Authority (FCA No. 588422). Registered in England and Wales.
