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RFJ
Three markets · one test

Islamic home finance, compared

Every home-finance provider we audit in the US, the UK and Canada, read against the same five questions, with the quote behind every answer.

Last reviewed1 October 2026Next review due1 January 2027Corrections log

The short answer

Where each market stands

27 providers still operating (5 of them only for some buyers, such as GCC residents, buy-to-let investors or very large balances), plus 2 collapsed or merged ones kept as warnings. The numbers below are counted from the scorecard further down, never typed by hand. In all three markets, most providers either tie the price to an interest benchmark or do not publish how it is set, and most do not publish what happens if you cannot pay.

United States

OCC / state regulators · SEC (investments)

7home-finance providers read (plus 1 defunct, shown as warnings)
Price pegged to an interest benchmark2 of 7
Rent set from market rent2 of 7
Default process published2 of 7
Title arrangement published5 of 7

Approved without a need condition: Ameen Housing Cooperative of California, Neeyah. Permissible only in need: Guidance Residential, UIF Corporation, Devon Bank. Not approved by an outside body: Ijara Community Development Corp.

The full United States audit

United Kingdom

FCA / PRA · FSCS-protected deposits

9home-finance providers read
Price pegged to an interest benchmark3 of 9
Rent set from market rent1 of 9
Default process published2 of 9
Title arrangement published5 of 9

No provider here has a ruling from a body outside the provider.

The full United Kingdom audit

Canada

OSFI (federal) · provincial regulators · CIRO (investments)

11home-finance providers read (plus 1 defunct, shown as warnings)
Price pegged to an interest benchmark1 of 11
Rent set from market rent0 of 11
Default process published2 of 11
Title arrangement published6 of 11

Permissible only in need: Manzil, EQRAZ. Not approved by an outside body: AYA Financial, Ijara CDC.

The full Canada audit

The method

Five questions, asked of every provider

01

Which contract

The structure the provider publicly describes.

02

Who holds title

Real ownership: does the financier (or a vehicle it owns) actually hold the home, or only a charge over yours?

03

How the price or rent is set

Rent vs interest: is the payment set from a market rent or a fixed sale price, or pegged to an interest benchmark?

04

What happens on default

Does default unwind like the end of a sale or partnership, or run like a loan foreclosure? Often not public.

05

Independent scholarly ruling

Has a body outside the provider ruled on this product? A provider's own board does not count.

Financiermatches what the classical conditions ask forDiminishing musharakahneither a strength nor a concern on its ownConventional benchmarka documented concern under the Six PillarsNot approved / impermissiblenot approved, or ruled impermissible, by an outside bodyNot publicly documentednot public, so it cannot be checked

Colours follow the site’s Six Pillars lens: they show how an answer sits against the classical conditions, not a ruling on any contract.

Across the three markets

The patterns, side by side

Each bar is one market’s providers, split by their answer to one question. Bars are proportions, so markets of different sizes compare fairly. Collapsed or merged providers are left out.

Who holds title

Real ownership: does the financier (or a vehicle it owns) actually hold the home, or only a charge over yours?

United States7 providers
2 Customer (financier holds a charge or lien)2 Joint1 Trust or SPV2 Not disclosed
United Kingdom9 providers
4 Financier1 Trust or SPV4 Not disclosed
Canada11 providers
1 Financier4 Customer (financier holds a charge or lien)1 Trust or SPV5 Not disclosed

How the price or rent is set

Rent vs interest: is the payment set from a market rent or a fixed sale price, or pegged to an interest benchmark?

United States7 providers
2 Conventional benchmark2 Market rent1 Fixed at signing2 Not disclosed
United Kingdom9 providers
3 Conventional benchmark1 Market rent5 Not disclosed
Canada11 providers
1 Conventional benchmark1 Fixed at signing9 Not disclosed

What happens on default

Does default unwind like the end of a sale or partnership, or run like a loan foreclosure? Often not public.

United States7 providers
1 Sale with surplus to customer1 Foreclosure or repossession5 Not publicly documented
United Kingdom9 providers
1 Sale with surplus to customer1 Mediation or accommodation7 Not publicly documented
Canada11 providers
2 Mediation or accommodation9 Not publicly documented

Independent scholarly ruling

Has a body outside the provider ruled on this product? A provider's own board does not count.

United States7 providers
2 Approved by an independent body3 Permissible only in need1 Not approved / impermissible1 No independent ruling found
United Kingdom9 providers
9 No independent ruling found
Canada11 providers
2 Permissible only in need2 Not approved / impermissible7 No independent ruling found

Provider by provider

The full scorecard

Open “Show the quotes” on any row to see the words each answer rests on. Names link to the full provider audit.

United States

Audit hub →
How home finance works here

Most US Islamic home finance uses one of two shapes. Declining-balance co-ownership (a Diminishing Mushārakah): the financier and you jointly buy the home, you pay 'rent' on the financier's share and buy that share down over time. Or a Murābaḥah/Ijārah: the financier buys the home and sells or leases it to you at a disclosed markup over instalments. Both are defensible in principle — the permissibility turns on whether the financier carries genuine ownership risk, whether the 'rent' tracks a real market rent or an interest index, and what happens on default. Read the executed contract, not the brochure.

  • Contract
    Diminishing musharakah
    Title held by
    Joint
    Pricing
    Conventional benchmark
    On default
    Sale with surplus to customer
    Independent ruling
    Permissible only in need
    Show the quotes behind these values
    • Contract“Guidance's published white paper describes a diminishing-mushārakah co-ownership: the customer and a Guidance affiliate become co-owners”
    • Title held by“Guidance normally goes on record as co-owner on the title”
    • Pricing“Guidance determines the Profit Payment offered to its customers to be competitive with prevailing interest rates”
    • On default“with any surplus to the customer”
    • Independent ruling“Guidance ruled PERMISSIBLE in the face of need”

    Note: In some states Guidance stays off title to avoid extra taxes.

  • Contract
    Diminishing musharakah
    Title held by
    Customer (financier holds a charge or lien)
    Pricing
    Conventional benchmark
    On default
    Foreclosure or repossession
    Independent ruling
    Permissible only in need
    Show the quotes behind these values
    • Contract“based on Mushārakah / Sharikatul Milk”
    • Title held by“The title is in your name from day one”
    • Pricing“We also track the mortgage industry pricing so that we stay competitive”
    • On default“UIF has the right to foreclose on the property and sell it in the open market, which could result in a loss”
    • Independent ruling“AMJA 2014 resolution: UIF ruled PERMISSIBLE only in dire need.”

    Note: UIF waives going on title but keeps a security instrument and a right to foreclose.

  • Contract
    Murabaha (cost-plus sale)
    Title held by
    Customer (financier holds a charge or lien)
    Pricing
    Fixed at signing
    On default
    Not publicly documented
    Independent ruling
    Permissible only in need
    Show the quotes behind these values
    • Contract“Devon Bank (Chicago; NMLS #412368) primarily uses Murābaḥah for residential purchase”
    • Title held by“so the customer holds title after the bank's brief intermediate purchase, secured by a lien/security instrument”
    • Pricing“calibrated to a market rate of return but fixed at contract, with no named interest index”
    • On default“so the precise default clause is not verified here”
    • Independent ruling“AMJA 2014 resolution: Devon Bank ruled PERMISSIBLE only in dire need (both contract types).”

    Note: Devon also had an ijārah product, and AMJA's ruling covered both.

  • Contract
    Unclear
    Title held by
    Not disclosed
    Pricing
    Not disclosed
    On default
    Not publicly documented
    Independent ruling
    Not approved / impermissible
    Show the quotes behind these values
    • Contract“the earlier descriptions we had conflict on whether LARIBA ever held a share of title or only a lien”
    • Title held by“conflict on whether LARIBA ever held a share of title or only a lien”
    • Pricing“Earlier descriptions say rent was set from market rental estimates rather than an interest index (not re-verifiable)”
    • On default“no executed LARIBA contract, note or lien instrument is public”
    • Independent ruling“AMJA 2014 resolution: LARIBA ruled IMPERMISSIBLE — the committee found its contract 'does not differ from a traditional mortgage' despite Islamic presentation.”

    Note: Merged into UIF on 1 April 2026 rather than collapsed. Its contract documents are no longer online, so only AMJA's rulings are verifiable.

  • Contract
    Ijarah (lease-to-own)
    Title held by
    Trust or SPV
    Pricing
    Not disclosed
    On default
    Not publicly documented
    Independent ruling
    Not approved / impermissible
    Show the quotes behind these values
    • Contract“(ijārah wa iqtinā) around a grantor trust”
    • Title held by“Title is held by the trust, but the customer is the trust's initial trustee and beneficiary using their own SSN/tax ID”
    • Pricing“the public materials do NOT state how the rent amount is calculated (no index, market-rent or formula disclosed)”
    • On default“do NOT describe the default/foreclosure mechanism or recourse to the customer/heirs”
    • Independent ruling“AMJA 2014 resolution ruled 'Ijara Loan' IMPERMISSIBLE — 'it is not allowed to deal with this company as their model contains clear and explicit interest'”

    Note: A nonprofit facilitator that works with partner lenders; the customer is the trust's trustee and beneficiary.

  • Contract
    Co-operative
    Title held by
    Joint
    Pricing
    Market rent
    On default
    Not publicly documented
    Independent ruling
    Approved by an independent body
    Show the quotes behind these values
    • Contract“Ameen Housing is a member-owned cooperative (self-described as a Shariah-compliant REIT-style cooperative; certified by AMJA) using a mushārakah co-ownership.”
    • Title held by“AHC and the member are both named on the title”
    • Pricing“Rent is calibrated to fair market rental value via professional appraisal, explicitly NOT to interest”
    • On default“the explicit default / non-payment mechanism and recourse are NOT documented in the public FAQ”
    • Independent ruling“AMJA ruled it PERMISSIBLE, stating 'the contracts that Ameen Housing is now using are consistent with the laws of the Shareeah'”

    Note: Invests only in California and Texas properties.

  • Neeyah
    High
    Contract
    Diminishing musharakah
    Title held by
    Not disclosed
    Pricing
    Market rent
    On default
    Not publicly documented
    Independent ruling
    Approved by an independent body
    Show the quotes behind these values
    • Contract“the homeowner buys out Neeyah's share incrementally over 15 years”
    • Title held by“the executed co-ownership agreement is not publicly posted; no NMLS number is publicly confirmable”
    • Pricing“The homeowner pays monthly rent on Neeyah's share at local market rates”
    • On default“the executed co-ownership agreement is not publicly posted”
    • Independent ruling“AMJA Resident Fatwa Committee, Fatwa ID 87782, issued 14 January 2026 (listed on AMJA's site 22 January) — the controlling Shariah opinion, which declared the contract acceptable”

    Note: A co-ownership model, but the text does not say how the buyer's share grows, how rent is set, who is on title or what happens on default.

  • Contract
    Ijarah (lease-to-own)
    Title held by
    Not disclosed
    Pricing
    Not disclosed
    On default
    Not publicly documented
    Independent ruling
    No independent ruling found
    Show the quotes behind these values
    • Contract“the buyer obtains a conventional interest-based mortgage first and the ijārah wrapper does not cure the interest”
    • Title held by“Confirm the exact executed contract and whether any conventional interest-bearing loan sits anywhere in the chain before proceeding.”
    • Pricing“Confirm the exact executed contract and whether any conventional interest-bearing loan sits anywhere in the chain before proceeding.”
    • On default“Confirm the exact executed contract and whether any conventional interest-bearing loan sits anywhere in the chain before proceeding.”
    • Independent ruling“AMJA does not name CMG”

    Note: CMG's own pages describe the same trust structure as Ijara CDC, which AMJA's 2014 resolution ruled not allowed; AMJA did not name CMG, so that ruling is not counted against CMG here.

United Kingdom

Audit hub →
How home finance works here

The UK calls its main product a Home Purchase Plan (HPP), regulated by the FCA. Most HPPs are a Diminishing Mushārakah (co-ownership you buy down) or an Ijārah (the bank owns the home and leases it to you, ownership transferring at the end). Because the providers include fully FCA/PRA-regulated Islamic banks, the regulatory and consumer-protection layer is the strongest in the West — but regulation is not the same as Shariah-compliance. The fiqh question is still whether the bank carries genuine ownership risk and whether the 'rent' is a real rent or an interest rate in disguise.

  • Contract
    Diminishing musharakah
    Title held by
    Financier
    Pricing
    Conventional benchmark
    On default
    Not publicly documented
    Independent ruling
    No independent ruling found
    Show the quotes behind these values
    • Contract“a diminishing mushārakah + ijārah where each acquisition payment grows the customer's share and shrinks the bank's”
    • Title held by“the bank holds legal title during the term ('the property is registered in our name') and transfers it to the customer on completion”
    • Pricing“Rent is benchmark-linked, NOT an independent market rent: products carry an Initial/Fixed Rental Rate for 2 or 5 years, then revert to a 'Follow-on Rental Rate' equal to the Standard Variable Rate (SVR)”
    • On default“Honest limit: the precise rent-calculation formula and the default/sale surplus-shortfall waterfall are not public”
    • Independent ruling“No arm's-length fatwa-body review beyond the bank's own Shariah board was located.”
  • StrideUp
    Medium
    Contract
    Diminishing musharakah
    Title held by
    Financier
    Pricing
    Not disclosed
    On default
    Not publicly documented
    Independent ruling
    No independent ruling found
    Show the quotes behind these values
    • Contract“StrideUp is an FCA-regulated (FRN 785299) non-bank HPP provider using diminishing mushārakah + ijārah”
    • Title held by“StrideUp holds legal title during the term — per IFG's review, 'Strideup buys the house – it is actually in their name – and will remain so – until you fully buy it from them'”
    • Pricing“the exact rent formula and margin, and the precise FSCS scope for the HPP are not published”
    • On default“Honest limit: the legal-title/default clauses, the exact rent formula and margin, and the precise FSCS scope for the HPP are not published”
    • Independent ruling“No internal Shariah board; products are independently certified by Amanah Advisors (the firm led by Mufti Faraz Adam).”

    Note: Amanah Advisors certifies in place of an in-house board, so it is not counted as an arm's-length ruling; the FAQ allows a Base Rate benchmark but does not confirm one is used.

  • Offa
    Medium
    Contract
    Diminishing musharakah
    Title held by
    Financier
    Pricing
    Not disclosed
    On default
    Not publicly documented
    Independent ruling
    No independent ruling found
    Show the quotes behind these values
    • Contract“Structure is co-ownership-with-leasing (diminishing mushārakah + ijārah)”
    • Title held by“Offa is the legal owner of the property. You will not become the legal owner until you have completed all your payments.”
    • Pricing“do NOT state whether rent tracks the Bank of England base rate, another benchmark, or an independent market rent”
    • On default“the default/sale waterfall, FSCS scope, and the executed contract set are all unpublished”
    • Independent ruling“No named independent scholar review located.”

    Note: The text says Amanah Advisors certifies the products, but that is the provider's own certifier, not an arm's-length ruling.

  • Contract
    Diminishing musharakah
    Title held by
    Trust or SPV
    Pricing
    Market rent
    On default
    Mediation or accommodation
    Independent ruling
    No independent ruling found
    Show the quotes behind these values
    • Contract“A non-bank provider positioning on a 'truly debt-free' diminishing-mushārakah model”
    • Title held by“the property is held by a special-purpose company, Pfida Finance PLC ('The legal freehold title will be owned by Pfida Finance PLC')”
    • Pricing“Pfida says 'The rent takes into account the local property market and several other factors, but not interest though'”
    • On default“a customer who cannot pay can sell equity shares back to Pfida instead of paying”
    • Independent ruling“examines the debt-free diminishing-mushārakah model — scholarly analysis rather than a fatwa endorsement”

    Note: Now trades as Pfida; what happens once the equity buffer runs out is not described.

  • Al Rayan BankRestricted
    High
    Contract
    Diminishing musharakah
    Title held by
    Financier
    Pricing
    Conventional benchmark
    On default
    Sale with surplus to customer
    Independent ruling
    No independent ruling found
    Show the quotes behind these values
    • Contract“a Diminishing Co-ownership Agreement (DCA / diminishing mushārakah), a Lease (ijārah), a Service Agency Agreement, and a Legal Charge”
    • Title held by“For the duration of this deed, legal title to the Property shall vest in us”
    • Pricing“Rent is benchmark-pegged, NOT a market rent: the 'Variable Rental Rate = Base Rate together with the Margin', Base Rate being the Bank of England rate”
    • On default“can then sell free of the customer's rights (DCA cl.6.3), and pays any surplus after an eight-tier waterfall”
    • Independent ruling“IFG is a review platform, not a fatwa body.”

    Note: Retail home finance for UK residents is temporarily withdrawn; Premier Home Finance is advertised to applicants from five GCC countries. A sale shortfall stays owed.

  • Contract
    Mixed
    Title held by
    Not disclosed
    Pricing
    Conventional benchmark
    On default
    Not publicly documented
    Independent ruling
    No independent ruling found
    Show the quotes behind these values
    • Contract“Its Ijārah HPP is a defensible co-ownership-plus-lease structure; but it also offers a Commodity Murābaḥa (Tawarruq) route”
    • Title held by“but the full HPP terms and the executed contract are not public”
    • Pricing“with rent "benchmarked against KFH PLC Base Rate (currently 3.75%) which tracks the Bank of England base rate"”
    • On default“the full HPP terms and the executed contract are not public”
    • Independent ruling“No external Shariah audit is publicly disclosed beyond the SSB's certification”

    Note: Intermediary-introduced only, £250,000 minimum; the base-rate benchmark is stated for the Ijārah HPP route.

  • Contract
    Murabaha (cost-plus sale)
    Title held by
    Not disclosed
    Pricing
    Not disclosed
    On default
    Not publicly documented
    Independent ruling
    No independent ruling found
    Show the quotes behind these values
    • Contract“offering "Shari'a-compliant property financing using Murabaha (cost-plus financing)" for London residential property”
    • Title held by“the executed terms are bespoke and not public. A buyer should review the full Murābaḥa contract with an independent adviser and confirm exactly when the bank takes legal title before resale.”
    • Pricing“QIB offers "either profit-only payments or amortisation plans, with fixed or variable profit rates"”
    • On default“the executed terms are bespoke and not public”
    • Independent ruling“No public external Shariah audit beyond SSB oversight; product-specific fatāwā are not published.”

    Note: Private banking with a £1,000,000 minimum relationship, London only.

  • BLME / NomoRestricted
    High
    Contract
    Commodity murabaha / tawarruq
    Title held by
    Not disclosed
    Pricing
    Not disclosed
    On default
    Not publicly documented
    Independent ruling
    No independent ruling found
    Show the quotes behind these values
    • Contract“Nomo's residential product uses Commodity Murābaḥa (a metal-commodity chain handled procedurally) rather than a direct property Murābaḥa or Ijārah”
    • Title held by“uses Commodity Murābaḥa (a metal-commodity chain handled procedurally) rather than a direct property Murābaḥa or Ijārah”
    • Pricing“The 'follow-on' variable-rate formula is not publicly disclosed.”
    • On default“early repayment carries no penalty but the deferred profit remains contractually owed plus a settlement fee”
    • Independent ruling“A March 2025 fatwa is cited as confirming the product's compliance; the full text is not publicly reproduced.”

    Note: Only for residents of GCC countries; the text does not describe title or default terms.

  • Contract
    Mixed
    Title held by
    Not disclosed
    Pricing
    Not disclosed
    On default
    Not publicly documented
    Independent ruling
    No independent ruling found
    Show the quotes behind these values
    • Contract“using "two modes of Islamic finance, namely Diminishing Musharaka and Commodity Murabaha", depending on the finance required”
    • Title held by“executed T&Cs are not public, so an investor should request the full agreement and the IFAAS certificate before committing”
    • Pricing“executed T&Cs are not public, so an investor should request the full agreement and the IFAAS certificate before committing”
    • On default“executed T&Cs are not public”
    • Independent ruling“which "oversees the Shariah compliance of our Sirat banking services and conducts regular compliance reviews and external Shariah audits" (HBZ)”

    Note: Buy-to-let and commercial property only, not homes to live in; it uses diminishing mushārakah or commodity murābaḥah depending on the finance.

How home finance works here

Canadian halal home finance is newer but moving fast. The common shapes are Murābaḥah (the provider buys the home and resells it to you at a disclosed markup over instalments) and Ijārah/co-ownership (lease-to-own or declining-balance shared ownership). A long-standing co-operative model (Ansar) also pools community capital. As everywhere, the fiqh test is genuine ownership + risk on the provider's side and a default that unwinds like a sale/lease, not a loan.

  • Manzil
    Medium
    Contract
    Mixed
    Title held by
    Not disclosed
    Pricing
    Not disclosed
    On default
    Not publicly documented
    Independent ruling
    Permissible only in need
    Show the quotes behind these values
    • Contract“Manzil offers two home-finance contracts: a Murābaḥa (cost-plus sale, fixed rate/term up to 25 years per the Manzil–IFAAS launch note) and a declining-balance diminishing Mushāraka”
    • Title held by“whether the mushāraka shows Manzil on title or only a registered charge are not public (AMJA implies title is NOT taken in Manzil's name)”
    • Pricing“Honest limit: the executed Murābaḥa and Mushāraka contracts, the exact profit-rate benchmark”
    • On default“the default/foreclosure & recourse clauses, the fee schedule”
    • Independent ruling“the Murābaḥa was ruled permissible OUT OF NEED on 28 Jan 2025, and the Mushāraka on 29 Jan 2025”

    Note: The murābaḥa price is fixed; the mushāraka rate is fixed for 2 to 5 years and then repriced.

  • EQRAZ
    High
    Contract
    Commodity murabaha / tawarruq
    Title held by
    Customer (financier holds a charge or lien)
    Pricing
    Not disclosed
    On default
    Not publicly documented
    Independent ruling
    Permissible only in need
    Show the quotes behind these values
    • Contract“the financier uses a Shariah-compliant commodity (not the home) as the underlying asset, sells it to the customer who on-sells it to the open market, generating cash to acquire the home”
    • Title held by“the customer is 'the legal and beneficial owner of the property,' keeping all appreciation and absorbing any loss; the borrower signs exactly two agreements — 'The Murabaha Agreement' and 'The Legal Mortgage Charge.'”
    • Pricing“Pricing is a posted profit rate on up-to-5-year renewable terms 'each at its respective rate' (i.e. repriced at renewal)”
    • On default“the full default/foreclosure escalation path (the 'Security' FAQ on default/negative-equity sale could not be captured)”
    • Independent ruling“AMJA's Canada Resident Fatwa Committee added an EQRAZ section dated 1 June 2026 ruling its murābaḥah 'permissible in cases of need'”

    Note: AMJA (June 2026) flagged its reliance on bank-style tawarruq. The posted rate is fixed for each term of up to 5 years and repriced at renewal; what sets it is not stated.

  • Contract
    Mixed
    Title held by
    Customer (financier holds a charge or lien)
    Pricing
    Not disclosed
    On default
    Mediation or accommodation
    Independent ruling
    No independent ruling found
    Show the quotes behind these values
    • Contract“Alberta-based CHFC offers both a Murābaḥa and a Mushāraka (diminishing co-ownership), each certified halal by a posted fatwa.”
    • Title held by“clients have full ownership rights and only our client's name is registered on the title and there are no third-party incumbrancers, such as banks, involved”
    • Pricing“secondary explainers describe the murābaḥa markup as benchmarked to the Bank of Canada overnight rate, but CHFC's own FAQ does NOT publish a benchmark or formula”
    • On default“Default is handled by accommodation rather than foreclosure: CHFC says it will 'work with you to help you resolve this problem'”
    • Independent ruling“Not addressed in the AMJA Canadian resolution”

    Note: Only the client is on title and CHFC says it registers no charge, so how it secures its share is not public. Al Rashid Mosque's finance committee ended its association in January 2024; CHFC says its newer contracts were approved by Al Azhar University, but no published ruling from that body is cited.

  • Contract
    Co-operative
    Title held by
    Financier
    Pricing
    Not disclosed
    On default
    Not publicly documented
    Independent ruling
    No independent ruling found
    Show the quotes behind these values
    • Contract“member and co-op jointly purchase the home, the member pays occupancy charges (rent) on the co-op's share and progressively buys the co-op's shares until owning the unit”
    • Title held by“the co-op 'transfers the title to the homeowner' (implying the co-op holds title until then)”
    • Pricing“how the occupancy-charge rate level is actually set, and fee/membership-share detail are not public”
    • On default“the executed occupancy/share agreement, the default and forced-sale recourse procedure”
    • Independent ruling“The AMJA resolution did not cover Ansar; no other named independent scholarly review is verifiable.”

    Note: The title point comes from secondary sources; Ansar's own page does not restate it.

  • Contract
    Diminishing musharakah
    Title held by
    Customer (financier holds a charge or lien)
    Pricing
    Conventional benchmark
    On default
    Mediation or accommodation
    Independent ruling
    No independent ruling found
    Show the quotes behind these values
    • Contract“ACU's product is a mushāraka 'Declining Partnership Agreement': the member contributes a minimum 20% and ACU the balance, establishing each party's percentage ownership.”
    • Title held by“i.e. customer-name title with ACU's interest secured as a registered mortgage charge (not title in ACU's name)”
    • Pricing“the profit is 'comparable to the best rate ACU would charge for a conventional, closed, fixed-rate mortgage”
    • On default“Default/hardship is handled non-coercively — the member 'may request assistance from a philanthropic source of your choice within the Muslim community'”
    • Independent ruling“No named independent scholar outside the ACU/Manitoba Islamic Association advisory arrangement is verifiable.”

    Note: Manitoba only; the foreclosure path if mediation fails is not public.

  • Contract
    Murabaha (cost-plus sale)
    Title held by
    Not disclosed
    Pricing
    Fixed at signing
    On default
    Not publicly documented
    Independent ruling
    No independent ruling found
    Show the quotes behind these values
    • Contract“Servus Halal buys the home from the seller and resells it to you under a Murabaha agreement”
    • Title held by“the title-registration mechanics (whose name on title after resale)”
    • Pricing“Pricing is uniquely fixed for the whole term: 25-year term and amortization, 'profit is calculated using a fixed profit rate for the term of the mortgage,'”
    • On default“the explicit default/foreclosure & mediation procedure are not public (the Al Rashid sub-page on default specifics returned 404)”
    • Independent ruling“CIFB (Dr. Muammar Sawan) is the certifier rather than a fully independent third party; no separate independent scholarly review was located.”
  • AYA FinancialIntermediary
    High
    Contract
    Unclear
    Title held by
    Not disclosed
    Pricing
    Not disclosed
    On default
    Not publicly documented
    Independent ruling
    Not approved / impermissible
    Show the quotes behind these values
    • Contract“the contracts do not reflect any shape or form of a musharakah”
    • Title held by“AYA's response/any remediation, title-registration mechanics and fee schedule are not documented”
    • Pricing“Honest limit: the contracts themselves are not public (only the fatwa's quotations of them)”
    • On default“the contracts themselves are not public (only the fatwa's quotations of them)”
    • Independent ruling“AMJA's Canada Resident Fatwa Committee (ruling dated 26 Feb 2025) did NOT approve AYA's mushāraka in its reviewed form”

    Note: AYA links buyers to the financier, Moya Financial; it is sold as diminishing mushāraka, but the reviewing fatwa says the documents work like a conventional mortgage.

  • Contract
    Diminishing musharakah
    Title held by
    Not disclosed
    Pricing
    Not disclosed
    On default
    Not publicly documented
    Independent ruling
    No independent ruling found
    Show the quotes behind these values
    • Contract“The diminishing-mushārakah structure itself was broadly sound”
    • Title held by“it is unclear who ultimately owns the home in the case of a bankruptcy by the lender, if legal title remains with the lender”
    • Pricing“Executed UM–homeowner contracts are not public.”
    • On default“Executed UM–homeowner contracts are not public.”
    • Independent ruling“Not assessed by AMJA. The Islamic Banking and Finance Network (IBFN) reposted a Reuters report on the collapse”

    Note: Collapsed into receivership in 2011; listed as a warning, not an option.

  • Tjara Halal FinancingIntermediary
    Medium
    Contract
    Diminishing musharakah
    Title held by
    Customer (financier holds a charge or lien)
    Pricing
    Not disclosed
    On default
    Not publicly documented
    Independent ruling
    No independent ruling found
    Show the quotes behind these values
    • Contract“The declining-balance co-ownership with the client on title from day one is the cleanest Canadian model for avoiding double land-transfer tax”
    • Title held by“The client holds legal title from day one (Tjara takes only a registered mortgage charge)”
    • Pricing“the executed contract text is not public, the usage-fee benchmark is undisclosed, and AMJA has not reviewed Tjara”
    • On default“the executed contract text is not public”
    • Independent ruling“no independent Canadian review was located”

    Note: Tjara says it is 'a referral agent' and that unnamed partner institutions provide the funding; its 2023 product fatwa is from its own advisory board.

  • Contract
    Co-operative
    Title held by
    Not disclosed
    Pricing
    Not disclosed
    On default
    Not publicly documented
    Independent ruling
    No independent ruling found
    Show the quotes behind these values
    • Contract“The co-op buys housing units in the Greater Montreal area and transfers them to members in good standing under a diminishing mushārakah”
    • Title held by“The gaps are governance and disclosure: no named independent Shariah board, no published contract”
    • Pricing“an undisclosed administration/management-fee basis (whether the fee is a fixed charge or proportional to actual co-op cost matters for permissibility)”
    • On default“no named, publicly-documented Shariah board could be located and the executed contract is not public”
    • Independent ruling“Not named in the AMJA 2025 Canada resolution; no public fatwa document located.”
  • Contract
    Co-operative
    Title held by
    Not disclosed
    Pricing
    Not disclosed
    On default
    Not publicly documented
    Independent ruling
    No independent ruling found
    Show the quotes behind these values
    • Contract“Members buy shares ($100/share, minimum six plus a membership fee); pooled funds purchase properties; monthly payments reduce the co-op's stake until title transfers.”
    • Title held by“the corporate boundary with Ansar (shared portal) makes title-holding less clear”
    • Pricing“the administration fee (if it is a fixed return regardless of property performance it edges toward guaranteed profit)”
    • On default“The executed member contract is not public and no Shariah audit was located.”
    • Independent ruling“Not named in the AMJA 2025 Canada resolution; no independent fatwa located.”

    Note: Title is said to transfer at the end, but the shared portal with Ansar blurs who holds it meanwhile.

  • Ijara CDC (Canada)Intermediary
    Medium
    Contract
    Ijarah (lease-to-own)
    Title held by
    Trust or SPV
    Pricing
    Not disclosed
    On default
    Not publicly documented
    Independent ruling
    Not approved / impermissible
    Show the quotes behind these values
    • Contract“Ijārah wa iqtinā is a recognised, AAOIFI/IIFA-approved contract”
    • Title held by“A trust purchases the property and leases it to the buyer under ijārah wa iqtinā, with title transferring for $1 at the end”
    • Pricing“Ijara's own pages do not describe the funding”
    • On default“No executed Canadian contract is public.”
    • Independent ruling“says it studied the contracts and concludes 'Ijara CDC is not Shariah Compliant'”

    Note: The interest link rests on an Askimam fatwa's statement that the trust buys through a conventional mortgage; Ijara's own pages do not describe the funding. Buyers can opt for an unrecorded deed that keeps them on title.

Peer-reviewed evidence

What the research says

11 journal articles and books from university and academic presses. Every quotation was matched word for word against the abstract or publisher description on 1 October 2026, and every DOI resolves. Most of this work studies Islamic banking in general, not Western home finance; each card says what it does and does not cover. The literature has a gap: we found no peer-reviewed study of default terms in Western Islamic home finance, and none at product level for Canada.

  1. Muhammad Hanif · 2019

    Islamic mortgages: principles and practice

    International Journal of Emerging Markets 14(5), 967–987

    “Study documents multiple divergences from Musharakah principles in the existing practice of Islamic mortgages including ignorance of market pricing in the negotiation of rentals and trading of equity units, and transfer of all ownership risks and rewards (vacancy, damage, destruction and market) to one partner (i.e. customer).”
    Abstract (Semantic Scholar record of the Emerald article)
    Speaks to:
    Who holds title and bears risk; how rent is set
    What it covers:
    About diminishing-mushārakah home finance in general; the abstract names no country, and part of the paper proposes the author's own model.
    What it means here:
    The two gaps this page tests most often, rent not set from market prices and ownership risk pushed onto the customer, are the same divergences this study documents.
    doi:10.1108/IJOEM-02-2018-0088
  2. Rosylin Mohd Yusof, Mejda Bahlous and Roszaini Haniffa · 2016

    Rental rate as an alternative pricing for Islamic home financing: An empirical investigation on the UK market

    International Journal of Housing Markets and Analysis 9(4), 601–626

    “the authors show that there is no short or long run dynamics between the rental rate and any form of interest rates”
    Abstract (Crossref record of the Emerald article)
    Speaks to:
    How rent is set
    What it covers:
    UK data. "The rental rate" in the quote is the authors' own proposed Islamic Rental Rate; the abstract says the UK rental price index itself is significantly related to interest-rate measures. It proposes a pricing method rather than auditing any provider's pricing.
    What it means here:
    The UK rent index moves with interest rates, but a rent-based rate the authors construct showed no short- or long-run link to them, and they suggest Islamic banks consider it for pricing. The UK rows on this page show which plans tie rent to a base rate and which set it from market rent.
    doi:10.1108/IJHMA-10-2015-0063
  3. Abu Umar Faruq Ahmad and A. K. M. Shahed · 2010

    Housing Finance of Australian Islamic Financial Service Providers (IFSPs): An Empirical Analysis from Shariah Perspectives

    IIUM Journal of Economics and Management 18(1), 1–43

    “appear to be traditional mortgage contracts where the borrower takes the risk and the lender gets a fixed rate of return”
    Abstract (journal landing page)
    Speaks to:
    Who bears risk; substance over form
    What it covers:
    Australian providers as they stood around 2010, in the authors' own words a discursive analysis; products have changed since.
    What it means here:
    An early academic look at Western Islamic home finance concluded the contracts appeared, in substance, to be conventional mortgages.
    Journal page
  4. Muhammad Hanif · 2016

    Economic substance or legal form: an evaluation of Islamic finance practice

    International Journal of Islamic and Middle Eastern Finance and Management 9(2), 277–295

    “It is found in the process that legally (legal form) contracts/products are in line with theory; however, economic substance is not very different from conventional counter parts.”
    Abstract (Ajman University research portal)
    Speaks to:
    Substance over form, across the main contract types
    What it covers:
    Covers murābaḥah, ijārah, diminishing mushārakah, ṣukūk and deposits; the abstract names no country.
    What it means here:
    Contracts can be correct on paper while the cash flows look conventional, which is why this page asks how each one works, not what it is called.
    doi:10.1108/IMEFM-07-2014-0078
  5. Mahmoud A. El-Gamal · 2006

    Islamic Finance: Law, Economics, and Practice

    Cambridge University Press

    “It shows that Islamic finance exists mainly as a form of rent-seeking legal-arbitrage. … This book proposes refocusing Islamic finance on substance rather than form.”
    Book description (Cambridge Core)
    Speaks to:
    Substance over form
    What it covers:
    An industry-wide critique, not a study of home finance. Here "rent-seeking" means extracting extra margin, not ijārah rent.
    What it means here:
    A leading academic critic argues the industry too often copies conventional products in legal form; his remedy, substance over form, is the test this page applies.
    doi:10.1017/CBO9780511753756
  6. Feisal Khan · 2010

    How 'Islamic' is Islamic Banking?

    Journal of Economic Behavior & Organization 76(3), 805–820

    “A preliminary investigation shows that, three decades after its introduction, there remain substantial divergences between IBF's ideals and its practices, and much of IBF still remains functionally indistinguishable from conventional banking.”
    Abstract (RePEc/IDEAS)
    Speaks to:
    Substance over form
    What it covers:
    Industry-wide and, in the author's word, preliminary; not about home finance.
    What it means here:
    The gap between the ideal and the product is a long-documented pattern, not a quirk of one market.
    doi:10.1016/j.jebo.2010.09.015
  7. Beng Soon Chong and Ming-Hua Liu · 2009

    Islamic banking: Interest-free or interest-based?

    Pacific-Basin Finance Journal 17(1), 125–144

    “Our study on Malaysia shows that only a negligible portion of Islamic bank financing is strictly PLS based and that Islamic deposits are not interest-free, but are closely pegged to conventional deposits.”
    Abstract (RePEc/IDEAS)
    Speaks to:
    How the price is set
    What it covers:
    Malaysian banks' financing and deposits, not Western home finance.
    What it means here:
    Returns that track conventional rates are a known pattern; on this page it shows up as rent pegged to a base rate or "competitive with" mortgage rates.
    doi:10.1016/j.pacfin.2007.12.003
  8. Rajesh K. Aggarwal and Tarik Yousef · 2000

    Islamic Banks and Investment Financing

    Journal of Money, Credit and Banking 32(1), 93–120

    “We study financial instruments used by Islamic banks and find that most are not based on profit-and-loss sharing (equity) but, instead, are very debt-like in nature.”
    Abstract (RePEc/IDEAS)
    Speaks to:
    Real partnership vs debt
    What it covers:
    Islamic bank financing in general. The authors model debt-like contracts as a rational response to the banks' contracting environment, an explanation rather than an endorsement.
    What it means here:
    Debt-like structures dominate Islamic financing generally. On this page the same pattern shows up where the financier holds only a charge over the customer's title rather than a share of the home.
    doi:10.2307/2601094
  9. Habib Ahmed and Nourah Mohammad Aleshaikh · 2014

    Debate on Tawarruq: Historical Discourse and Current Rulings

    Arab Law Quarterly 28(3), 278–294

    “The practice of organized tawarruq by the Islamic financial industry, however, appears to be inconsistent with both the contemporary and historical rulings.”
    Abstract (Crossref record deposited by the publisher)
    Speaks to:
    Which contract (commodity murābaḥah / tawarruq)
    What it covers:
    A review of juristic rulings, not an empirical test of any provider.
    What it means here:
    Several UK and Canadian routes use commodity murābaḥah. This review finds the organised form at odds with both classical and contemporary rulings.
    doi:10.1163/15730255-12341282
  10. Ahmed Mansoor Alkhan and M. Kabir Hassan · 2019

    Tawarruq: Controversial or Acceptable?

    Arab Law Quarterly 33(4), 307–333

    “this article suggests that the general practice of organised tawarruq might be permissible”
    Abstract (Crossref record deposited by the publisher)
    Speaks to:
    Which contract (commodity murābaḥah / tawarruq)
    What it covers:
    The defence side, based on a qualitative look at three Bahraini banks; note the word "might".
    What it means here:
    The tawarruq question is genuinely contested in the literature, which is why this page marks it as a concern rather than a verdict.
    doi:10.1163/15730255-12334042
  11. Thorsten Beck, Asli Demirgüç-Kunt and Ouarda Merrouche · 2013

    Islamic vs. conventional banking: Business model, efficiency and stability

    Journal of Banking & Finance 37(2), 433–447

    “When comparing conventional and Islamic banks, controlling for time-variant country-fixed effects, we find few significant differences in business orientation”
    Abstract (RePEc/IDEAS)
    Speaks to:
    Substance over form, at bank level
    What it covers:
    Bank-level, cross-country data; says nothing about a particular product.
    What it means here:
    At the level of whole banks, Islamic and conventional banks look alike in what they do, which keeps the burden of proof on each product.
    doi:10.1016/j.jbankfin.2012.09.016

Method and limits

How this page is built

  • Scope: every provider in our US, UK and Canada audits that offers home finance (or a bank that does), including restricted ones (GCC residents only, buy-to-let only, high minimums), intermediaries, and two collapsed or merged firms kept as warnings. Pure investing apps are left out. Australia’s providers have their own audit at /audit.
  • Every answer is tied to a quotation from that provider’s audited entry. A test in the site’s code (app/lib/scorecard.test.ts) checks that each quotation still appears word for word, so a corrected entry cannot leave a stale answer behind.
  • “Not public” means we could not find it in the provider’s published material, not that it does not exist. Providers can send us documents through the contact page and we will update their row.
  • A provider’s own Shariah board or paid certifier is not counted as an independent ruling. That is a choice about independence, not a judgment of those scholars.
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