As she is has not lived an entire calendar year abroad and she did not meet the 330 foreign presence test in 2019, she should use the filing requirement for individuals living in the US. Her filing requirement for Form 8938 is as follow:
Specified individuals living in the US:
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Unmarried individual (or married filing separately): Total value of assets was more than $50,000 on the last day of the tax year, or more than $75,000 at any time during the year.
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Married individual filing jointly: Total value of assets was more than $100,000 on the last day of the tax year, or more than $150,000 at any time during the year.
For 2020 filing, she will need to follow the guidelines for specified individuals living outside the US if she is still living overseas.
Comparison of Form 8938 and FBAR Requirements
Instructions for Form 8938 (see page 3).
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