Over the past year, I have had more conversations than ever with Canadian private lenders asking
a deceptively simple question: should we be looking at the United States? Five years ago, that
question was relatively uncommon. Today, it comes up constantly—and for good reason.
The numbers tell an interesting story. In 2024, more than 106,000 Canadians emigrated from
Canada, the highest level recorded since 1967. Canadian investors now hold approximately CAD
$3 trillion in U.S. portfolio investments, while Canadian direct investment in the United States
exceeds CAD $1.2 trillion. Even the Canada Pension Plan Investment Board has nearly half of its
$714 billion portfolio deployed south of the border.
Whether the drivers are economics, diversification, demographics, or simple opportunity, the
conclusion is the same: Canadian people and Canadian capital are moving beyond Canada’s
borders—and the private lending industry should be paying attention. That is true for Canadian
lenders weighing their first U.S. loan, and it is equally true for the U.S. lenders, brokers, fund
managers, and sponsors who stand to benefit from a new wave of inbound capital.
Capital Follows Opportunity
Canada remains an important and attractive market for private lending. But many Canadian
lenders are facing headwinds that were less pronounced a decade ago: transaction volumes have
slowed in certain regions, competition for quality deals has intensified, borrowers are navigating
economic uncertainty, and real estate markets that once appeared unstoppable have become
more selective and more complex.
At the same time, the United States continues to offer scale that simply does not exist in Canada.
With a population approaching 350 million, a mature private lending industry, and thousands of
active opportunities across residential, commercial, construction, bridge, DSCR, and investor
lending, the U.S. market presents a meaningful growth and diversification path for lenders ready
to pursue it.
For many
For many Canadian lenders, the question is no longer whether
opportunity exists in the United States. The question is how to
access it.
An Opportunity on Both Sides of the Border
This trend matters to more than just Canadian lenders. As Canadian capital crosses the border, it
needs borrowers, projects, operators, and trusted relationships on the U.S. side.
For U.S. mortgage brokers, that means new sources of funding for qualified borrowers. For fund
managers and syndicators, it means a fresh pool of investors and capital partners actively seeking
geographic diversification. For borrowers and sponsors, it can mean access to capital sources
that were not previously available. In many respects, we are witnessing the early stages of a
broader cross-border capital movement—and the participants who position themselves now will
be the ones who benefit most.
Fifty Markets, Not One
Of course, expanding into the United States is not as simple as funding a loan. One of the most
common misconceptions among Canadian lenders is that the U.S. operates as a single lending
market. In reality, there are fifty separate jurisdictions, each with its own licensing requirements,
regulatory frameworks, foreclosure procedures, compliance obligations, and lending laws.
The rules governing a business-purpose loan in California may differ significantly from those in
Florida, Texas, Arizona, or New York. Foreclosure timelines vary. Licensing requirements vary.
Documentation and enforcement rights vary. The lenders who succeed in the United States are
typically not the ones who move the fastest—they are the ones who invest the time to understand
the rules before deploying capital.
A Broader Trend Worth Watching
One reason I believe this trend will continue is that it extends well beyond private lending.
Canadian wealth has become increasingly mobile. Canada’s tax system already recognizes this
reality: individuals who cease Canadian tax residency may be subject to the departure tax regime,
which can trigger consequences on certain unrealized gains upon leaving the country. The very
existence of those rules reflects a longstanding recognition that people, businesses, and capital
can—and do—move across borders.
At the institutional level, significant Canadian capital is already invested in the United States
through pension funds, private equity, public markets, real estate holdings, and direct business
investment. The movement is already happening. Private lenders simply have to decide whether
they want to participate.
How Geraci LLP Helps Lenders Cross the Border
As these conversations became more frequent, I found myself in a unique position. Having
practiced law in Canada for more than twenty years, and now serving as Chief Operating Officer of
Geraci LLP, I work with private lenders on both sides of the border every day. I understand the realities of the Canadian lending market because I built my legal career there—and I now operate
within the most active private lending legal ecosystem in the United States.
Canadian lenders exploring the U.S. tend to ask the same questions: Which states make the most
sense? Do we require licensing? How do foreclosure rights differ? What business structure should
we use? Who should be on our team? How do we enter the market strategically rather than
reactively?
To answer them, Geraci LLP now works hand in hand with my Toronto-based firm, Jasmine Daya
& Co., which provides dedicated cross-border strategic counsel to Canadian private lenders.
Together, our teams guide lenders through every stage of U.S. market entry—market selection,
licensing strategy, entity structuring, compliance, loan documentation, foreclosure, and risk
management. For most lenders, the challenge is not identifying the opportunity. The challenge is
pursuing it responsibly.
Looking Ahead
Not every Canadian private lender should expand into the United States—but every lender should
understand what opportunities exist there. The data suggests that Canadian people, Canadian
businesses, and Canadian capital are increasingly looking beyond their borders, and the private
lending industry is unlikely to be an exception.
For lenders willing to think strategically, build the right team, and understand the regulatory
landscape, the United States may represent one of the most significant growth opportunities of the
next decade. The capital is already moving. The question is whether you intend to move with it.
Considering a cross-border strategy?
Whether you are a Canadian lender evaluating your first U.S. loan or a U.S. lender, broker, or fund
manager looking to connect with inbound Canadian capital, our team can help. Contact Jasmine
Daya at Geraci LLP at (949) 403-3488, or join us at the Elevate Private Lenders Boot Camp,
September 28 – October 1, 2026, at the Fontainebleau Miami Beach, where cross-border capital
will be front and center.
