If none of the rules under Who Must File instructions for a Form 3520 apply to your situation, then you are not required to file the Form 3520.
However, you may be required to file either a Form 8938 or a FinCEN Form 114 (FBAR) based upon the amount of foreign assets you own.
Go to this IRS website for a Comparison of Form 8938 and FBAR requirements - https://www.irs.gov/businesses/comparison-of-form-8938-and-fbar-requirements
