The returning expat problem: what banks miss when customers move home
Cross-border financial lives are becoming more common, but credit data still rarely moves as easily as people do.
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An Estonian customer spends more than ten years living and working in Finland. During that time, they build a strong financial history: a mortgage, a car loan and a perfect repayment record.
Then they move back to Estonia and apply for a mortgage. Their financial behaviour has not changed. But much of the information that demonstrates it is still in Finland.
For the Estonian bank assessing the application, this creates a data gap. A domestic credit check provides the information available in Estonia, but it does not automatically show the financial history the customer built during more than a decade in Finland.
A financially experienced customer can therefore appear to have limited credit history simply because that history was built in another country.
More Europeans are building financial lives across borders
The Finland-Estonia example reflects a much broader reality across Europe. Around 45 million Europeans are mobile or have financial lives that span more than one country. People move for work, study, family or other opportunities. Some stay abroad permanently. Others return home after five, ten or twenty years.
During that time, they continue building their financial history. They take out mortgages, use credit cards, finance cars and repay loans. When they move again, the customer moves, but their financial information does not automatically move with them.
This creates a growing group of customers whose financial history cannot be understood through domestic data alone.
A thin local file does not mean a thin financial history
Consider the customer returning from Finland to Estonia. An Estonian bank may see limited recent local credit activity. If the customer has spent most of their working life abroad, this is completely logical.
What the bank may not see is ten years of repayment behaviour in Finland. Limited domestic information does not necessarily indicate limited credit experience or higher risk. It can simply mean that the relevant information sits in another country.
For credit teams, access to cross-border information makes it possible to separate these situations. Instead of assessing the customer mainly through what is available locally, the bank can include verified financial history from the countries where that history was actually built.
The same issue appears across Europe
A returning expat is only one example.
A Portuguese citizen may spend years working and borrowing in Germany before returning to Portugal. A Romanian customer may build their financial history in Italy and later move home. A French citizen may return after a decade in Belgium.
The countries change, but the underlying credit assessment challenge stays the same: relevant information about the customer is fragmented across national systems.
For banks, this becomes increasingly important as more customers have financial activity across multiple countries.
Mifundo connects cross-border credit data and enriches it with open banking data, giving banks access to a more complete financial picture through one platform. Verified information from different countries can be standardised and incorporated into the bank's existing credit assessment process.
The bank still makes the credit decision according to its own policies, models and risk appetite. The difference is the information available when making that decision.
CCD2 adds another reason to address the data gap
From 20 November 2026, the revised Consumer Credit Directive (CCD2) will apply across the European Union.
Article 6 introduces a non-discrimination requirement for consumer credit. Banks are not required to enter new markets, approve cross-border customers or change their risk appetite. They remain responsible for deciding whom they lend to and under what conditions.
However, the conditions for obtaining credit should not discriminate against consumers legally resident in the EU on the basis of nationality or place of residence.
For banks assessing customers whose financial histories span several EU countries, the ability to access relevant cross-border information therefore becomes increasingly important.
A customer returning home after ten years abroad has not lost those ten years of financial behaviour. The challenge for European banks is making sure their credit assessment can see it.
Explore how Mifundo helps banks assess cross-border financial histories at mifundo.com.
