COHEN ON REAL ESTATE

A global tour of how commercial real estate trades—and why the U.S. process might be due for a rethink.

In American commercial real estate, we take it as gospel:
The buyer makes the offer.
The property is “tied up.”
Then comes a parade of contingencies, attorneys, appraisals, lender delays, environmental reports, committee reviews, and at least three mysterious weeks of “just waiting on signatures.”

And after all that?
Maybe… just maybe… you have a deal.

But travel the world—and you’ll quickly learn:

The U.S. process is the slowest, most buyer-friendly system out there.
Sometimes, painfully so.

Let’s take a global tour of how CRE trades in other countries—and why you might want to reconsider how long your deal is taking.

🇺🇸 United States: The Buyer Rules the World

• Deals take months, not weeks.
• Buyers submit an LOI, tie the property up, and begin the long process of seeing whether they actually want it.
• Meanwhile, the seller quietly pays taxes, utilities, insurance, and hopes no one rips out the copper piping.
• Contingencies are the buyer’s safety net—and the seller’s purgatory.
• Bottom line: The buyer holds the cards. The seller holds the bag (and the property taxes).

🇬🇧 United Kingdom: Say Hello to Gazumping

• In the UK, you can accept an offer—but until contracts are signed, it’s just a polite suggestion.
• A new buyer can swoop in with a higher offer five minutes before closing, and boom—your deal’s gone.
• This charming act of betrayal is called “gazumping” (which sounds like something that happens after bad curry).
• CRE takeaway: Nothing is real until it’s signed. And sometimes not even then.

🇦🇺 Australia: Auction Nation

• Commercial and residential properties often go to auction, publicly and competitively.
• Buyers come pre-approved, due diligence done, and once the gavel drops, the deal is locked.
• There are no “we need to talk to our lender” or “the managing partner is on vacation” delays.
• Bottom-up pricing model: Start low, let the market climb.
• Result: Certainty, speed, and zero patience for tire-kickers.

🇫🇷 France: Bureaucracy Meets Real Estate

• Every transaction is overseen by a notaire (a sort of real estate referee with legal power and an impressive stamp collection).
• The buyer gets a 10-day cooling-off period to change their mind, but after that? It’s happening.
• CRE in France is elegant, paperwork-heavy, and very… French.
• Lesson: Structure and third-party control provide predictability—just not speed.

🇨🇳 China: You Own the Building, Not the Dirt

• All land is technically owned by the state. What you get is a 70-year leasehold, which makes valuing long-term commercial assets… interesting.
• Developers often buy land-use rights at public auction, and everything is built on leased land.
• When the lease expires? That’s a conversation with the government.
• CRE twist: Imagine underwriting a ground lease with a 70-year fuse and no promise of renewal.

🇧🇷 Brazil: Great Views, Murky Titles

• Due diligence is practically a sport in Brazil, where title issues, inheritance claims, and unclear boundaries are common.
• Title insurance isn’t the norm, so a good lawyer is your best broker.
• CRE investors learn quickly: If the ROI looks too good, dig deeper—or dig a moat.

🇩🇪 Germany: No Haggling, No Fuss

• CRE pricing in Germany is a take-it-or-leave-it affair.
• Asking prices are typically firm, and negotiations are minimal.
• The process is direct, efficient, and refreshingly un-American.
• Takeaway: If your buyer loves the thrill of “beating the seller down,” they should look elsewhere.

🧭 What This Means for American Sellers

If you’re in the U.S. waiting on a buyer to “circle back,” “run it by the IC,” or “finalize financing,” just know this:

The rest of the world trades real estate with more urgency, less friction, and—dare we say—more common sense.

That’s why auction is such a compelling model here in the States. It introduces speed, transparency, and competitive tension into a system that’s usually built for slow walkers and second thoughts.

🏁 Final Thought

There’s no one-size-fits-all model. But if you’re a U.S. seller tired of:

• Endless “diligence”
• Deal fatigue
• And buyers who ghost like bad dates…

Try selling like they do in Sydney. Or London. Or Shanghai.
Or just call us. We’ll bring the world to your property—and have it sold before your last buyer finishes their underwriting checklist.