I was asked to help with the MLR. For Non-Resident Aliens, one FAQ says "the bank is required to report the geographies from which the NRA customers originate.

We are debating as to what originate means. We have customers that live in Mexico but they are Canadian Citizens (the Mennonites). I sided with reporting them in the Mexico field and the BSA Officer says to report them as Canada. Which is it? Thanks for any help.

Only the OCC can know for sure. But if they are not US residence, I think they want to know their actual residency not where they are currently living.

rlcarey's right, it's not an NRA question, it's a question for the OCC because it revolves around how they want their form completed. My guess: They're assuming that you ID'ed your NRA's with a passport and they want the country of issuance. Alternatively, the country listed on their W8-BEN if you have one. Of course, they could have just asked you that...

We haven't asked the OCC. We have been reporting the passport's country of issuance as the BSA officer stated. I guess I'll leave this alone and stay with these answers.

Thank you very much to you both!