Rates – At present variable rates in France (and throughout the Euro zone) are about 2% cheaper than sterling rates and have been so for the last few years.
Mortgage types –
Interest Only is now quite common in the UK but is rare in France, where Repayment Mortgages are predominant.
Duration – Whilst the average duration in France is around 15 years some lenders now offer up to 25 years. However this is still far from the maximum mortgage term in the UK.
Consumer protection – Stronger in France, giving rise to more formalism e.g. use of postal system for sending and returning offers and compulsory 10 day consideration period. It also makes lenders more demanding for their risk assessment, seeking more information and ruling out for example the possibility of self assessment mortgages, (see next question). However the positive side of this consumer protection allows buyers to recover their deposit if their mortgage application is refused.
Valuations or surveys – French lenders do not generally require full structural surveys as in the UK, although some lenders in France do arrange for valuations to be carried out for their own internal use.
That said – what do they have in common? At the end of the day we find the same principle of taking a legal charge on the property financed, and the fact that your home is at risk if you do not keep up repayments.