Hello!
I am in the same boat. I was unaware of PFIC and although I have included the ULIP-linked Policy in FBAR as an account for several years, I was not filing Form 8621 myself. Neither TurboTax nor the other software I have been using recently (HRB) prompted me during their tax prep questionnaire.
I just checked the complete list of forms available in their software (I used the download version) for the last couple of years, and Form 8621 is not part of it at all. So it looks like that will need to be done on your own OR you have to get a tax preparer to work with you.
I am also checking with a local CPA whose initial response was that unless it is realized (i.e., you have sold or surrendered the policy and the proceeds have been credited back to your bank account), Form 8621 does not need to be filed. They are going to double-check and come back to me on that.
