I used to think it was somewhat questionable to use a US residential address while living overseas. But 26 years abroad has given me a lot of time to learn about it.
One thing for certain, there is nothing illegal about providing a US address despite not living in the US. Anyone who tells you otherwise is either misinformed or is trying to sell you something. You are well within your rights.
On the rare occasions when I’ve been asked directly by my US FI about where I live, I just tell them that I work overseas. They have never pried any further about my actual residence.
I have observed there are 3 categories of US FI. The first are the “blissfully unaware” — the small credit unions that have no exposure to the world. Second are the “running scared” types — they just know it’s a risk and decided it’s not worth their time or trouble. Third are the “well informed” — they are smart enough to know that by you giving them a US address, that gives them enough legal cover in case any issues come up.
What kind of issues you might ask? Here are a few examples:
Like the US, foreign jurisdictions often have laws regarding consumer protections and disclosures that apply to any residents who may live there, this is especially so in places like Europe. Failure to comply can bring legal action on the FI for failing to comply, when they have account holders who clearly live there based on their address.
Within the US, most traditional mutual funds have terms and conditions that restrict their sale to US residents only. If a US FI sells a MF to you while knowing you are not residing in the US, it is violating those terms and could get in trouble.
You will notice I haven’t mentioned the Patriot Act, and for good reason, there really isn’t anything in there that prevents a US FI from working with customers abroad. The rules about identifying suspicious transactions and the like, apply to all accounts, no matter what address is tied to it.