Theoretical foundations of mortgage lending and foreign models: the experience of the USA, Germany, Kazakhstan and Malaysia

Abstract

The article examines the theoretical foundations of mortgage lending and compares mortgage funding models of the United States, Germany, Kazakhstan and Malaysia using official statistics for 2021–2025. Four system types are identified: securitisation-based, covered-bond-based, contractual-savings with state subsidies, and a refinancing-and-guarantee model. The findings suggest that system resilience depends on maturity matching of funding, explicit risk allocation and the transparency of state support. Practical implications for Uzbekistan are formulated.