The rules seem to have changed for 2020 - this is from the Form 8938 instructions:
What’s New
Rev. Proc. 2020-17, available at IRS.gov/pub/irs-drop/rp-20-17.pdf, exempts foreign trust information reporting requirements on Forms 3520 and 3520-A, for certain U.S. individuals’ transactions with, and ownership of, certain tax-favored foreign trusts that are established and operated exclusively or almost exclusively to provide pension or retirement benefits, or to provide medical disability or educational benefits. This does not affect any reporting obligations under section 6038D. For more information about section 6038D information reporting, see IRS.gov/Businesses/ Corporations/Basic-Questions-and- Answers-on-Form-8938