Abstract
This paper conducts a comparative analysis of housing finance markets in the United States, United Kingdom, and Germany, focusing on their responses to market changes and significant external shocks like the Global Financial Crisis (GFC) and the COVID-19 pandemic. It aims to clarify the complex relationship between market dynamics and housing finance structures, as well as the impact of major market shocks on these systems. The study uncovers subtle differences in responses, underscored by governmental interventions, levels of securitisation, and diverse funding models of mortgage originators. It also highlights how regulatory interventions influence variations across markets in specific circumstances such as the GFC and the pandemic. This research contributes valuable insights into the adaptability and resilience of housing finance systems against external shocks, enhancing our understanding of their strengths and vulnerabilities.
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