The Country Files — with Marc Elliott, Fluent Finance Abroad
Buying a home on the Costa del Sol is a dream shared by thousands of British nationals every year. But for many English buyers, the Spanish mortgage system comes as a surprise — and sometimes a costly one. In this episode of The Country Files, Peter Franke, co-founder of Franke & de la Fuente Abogados, sits down with Marc Elliott of Fluent Finance Abroad to unpack the key differences between the UK and Spanish mortgage markets, and why understanding them before you buy is essential.
Who Is Marc Elliott?
Marc Elliott grew up between two worlds. Born in London to a Spanish mother from Madrid, he built his career in the UK mortgage industry — training with Scottish Widows and specialising at John Charcol, one of Britain’s longest-running mortgage brokers. In 2004, he made the move to Spain, and in 2006 — just before the global credit crisis — he founded what is now known as Fluent Finance Abroad. He has been advising international buyers on the Costa del Sol ever since.
The UK Mortgage Market: A Foundation of Regulation and Choice
To understand why English buyers are sometimes caught off guard in Spain, it helps to understand what they are used to at home.
In the UK, the mortgage broker has become the dominant force in property finance. According to Marc Elliott, “75% of all mortgages get arranged by independent mortgage brokers” — a figure that has nearly doubled over the past two decades. The reason, he explains, is straightforward: regulated brokers offer something banks simply cannot.
“a bank will only give you, or will only try and fit you into their box and will only give you one solution.”
— Marc Elliott, Fluent Finance Abroad
The UK mortgage market currently has around 120 active lenders, with thousands of products sold in tranches — fixed-rate deals at two, five, or more years, interest-only options, and refinancing arrangements for almost any legal purpose. Regulation is strict: brokers must hold the Certificate of Mortgage Advice and Practice (CeMAP), be registered with the Financial Conduct Authority (FCA), and can be permanently struck off for misconduct — much like a doctor or a lawyer.
As Peter Franke notes, this environment means English buyers arrive in Spain with a certain set of expectations — and a high degree of comfort around working with mortgage intermediaries. The challenge is that the Spanish system, while equally rigorous, operates on very different principles.
Spain Is Not the Same — and That Gap Can Cost You
The first thing Marc Elliott emphasises is deceptively simple: “buying a property is serious business, as you know, so you need to make sure it’s done in the right way.”
In Spain, mortgage lending is governed by the Ley de Contratos de Créditos Inmobiliarios (LCCI), which applies to virtually every mortgage — residential or investment — with very little distinction. This stands in sharp contrast to the UK, where buy-to-let mortgages, holiday lets, and bridging finance on non-residential properties fall outside FCA regulation entirely. In Spain, that separation does not exist, which is one of the main reasons why there is no true buy-to-let mortgage market here.
Spain also has far fewer lenders — primarily the high-street banks such as Santander, BBVA, Sabadell, Bankinter, and CaixaBank — and significantly fewer products. Marc Elliott is direct on this point: “we need more competition, we need more lenders to have a healthy market.” There is a secondary, private lending market, but it functions as short-term bridging finance at high cost — what Marc describes as “emergency money” to be accessed only when no other option exists.
The product range in Spain has improved. A hybrid mortgage known as mixto — part fixed rate, part variable — has become available in recent years, and Marc notes it is the product “the English person will understand” because it mirrors the fixed-rate deals they are familiar with at home. But the menu remains limited compared to the UK, and “it’s the differences that can trip you up.”
Refinancing: A Common Misconception
One of the most frequent misunderstandings Peter Franke encounters in his practice concerns refinancing. In the UK, releasing equity from a property you already own is straightforward — lenders will allow it up to around 75% loan-to-value for almost any legal purpose. In Spain, the rules are far more restrictive.
Marc Elliott illustrates with a scenario he encounters regularly: an English or Swedish buyer who purchased their Costa del Sol property outright in cash, and later assumes they can draw down funds against it — perhaps to pay off debt in their home country. The answer, he is clear, is no:
“I bought it cash 2 years ago, I need now to release funds because I want to send it back to Sweden because interest rates are high in Sweden. I want to pay down some debt in Sweden. That’s not going to happen. They will not allow it.”
— Marc Elliott, Fluent Finance Abroad
A Spanish bank may consider refinancing where funds are being reinvested directly into the property — for renovation or structural works, for example — but releasing equity for external purposes is generally not entertained. Peter Franke reinforces the point from a legal perspective, noting that buyers who mention refinancing as a future plan often need to be redirected: “we have to advise them that’s probably not going to be possible. You have to look into that now.”
The practical implication is clear: if a mortgage is part of the picture, it must be explored before the purchase decision is made — not after.
The Notary Process: A Different Kind of Ceremony
For English buyers, the formalities of completing a property purchase in Spain can be striking. In the UK, conveyancing is handled by solicitors; contracts are signed, exchanged, and completed without ceremony. In Spain, the notary sits at the centre of the entire transaction — and the signing is an event in itself.
Marc Elliott recalls his own first encounter with the process: “the whole notary thing is alien to — it was alien to me when I first came here.” He describes the notary signing as something approaching theatre:
“the whole process of signing the purchase contract at notary with all the stakeholders there, you know, it’s a bit like an opera.”
— Marc Elliott, Fluent Finance Abroad
Peter Franke agrees — “it’s a ceremony. It’s incredible. Sometimes it takes hours.” — and explains why that formality exists. Under Spain’s mortgage law, a bank must issue a binding offer (the FEIN) at least ten days before the signing date. The buyer — or their legal representative holding power of attorney — must then attend the notary in person to confirm they understand the terms. This rule was introduced to prevent banks from altering conditions at the last minute, a practice that Marc confirms was not unheard of before the legislation came into force.
The result is a timeline that typically runs two to three months from mortgage application to completion — broadly similar to the UK, though for different structural reasons.
The Single Most Important Piece of Advice
Both Peter Franke and Marc Elliott are consistent on one point above all others. The Spanish mortgage market is not a harder version of the UK mortgage market. It is a different one — with its own logic, its own constraints, and its own risks for the uninformed buyer.
“Do not assume that it is. Always speak to someone first. If you’re thinking about mortgages in Spain, speak to someone who actually knows, because you’d be surprised how different it is.”
— Marc Elliott, Fluent Finance Abroad
And the stakes are real. Beyond losing time — a failed mortgage application can delay or derail an entire purchase — buyers who proceed without proper advice “run the risk of maybe losing some money,” as Marc puts it simply. Which, as he adds, “is never nice.”
This article is based on a conversation recorded for The Country Files, a podcast series by Franke & de la Fuente Abogados exploring the property-buying experience of international buyers on the Costa del Sol.
