How would you define "Out Of Market Client" for BSA risk rating purposes? In our case, we are questioning whether the seasonal foreign customers we have at one of our branches would fall into this category, as well as a category for Non US citizens.

This is apparently an internal term. Accordingly, you may define it any way you wish, but you should do it so others will know what you are talking about.

If I were guessing about what a bank meant by using the term I would assume it reflected customers who were not located in the geographies it mentioned in its risk assessment (presumably its CRA assessment area).

These customers dwell in our market while they work here in the summer, then go back to their respective countries.

I would not consider that person "out of market" - for the same reason Ken stated. The assumption is that the customer is not in your market by the term "out of market."

Is it necessary to classify these seasonal customers using some specific term?

We include the seasonal workers you mentioned in our NRA risk rating. We apply the "Out of Market" risk rating to BUSINESS customers that are located outside of our CRA area.