Tax deferred status is not a factor in "Specified Foreign Assets." Here is a link to an IRS table that may help. I believe the "Financial Account held in a foreign institution" probably fits your asset. That is reportable on the 8938.
Additionally, it is the "aggregate" of all specified foreign assets that determines whether you meet the reporting threshold.
The disclosure is a letter to the IRS and I recommend a tax professional assist with that disclosure letter.
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