It mentions to file the returns together with any required information returns (e.g., Forms 3520, 3520-A, 5471, 5472, 8938, 926, and 8621) even if these information returns would normally not be submitted with the Form 1040 had the taxpayer filed a complete and accurate original return. According to the instructions, these would be included in the return even those these would be blank, which doesn't make sense.
My suggestion would be just to amend 2022 and include in your detailed statement that the instructions are not completely clear to you why you would need to amend 2020-2021 because it doesn't make sense to submit a blank 8938. In fact, Turbo Tax will not even generate this form unless you had a financial asset to report for that year unless the pension existed during those years and you were a US citizen in those years.
As far as the FBAR does, contact them here and ask them if they can provide you with more clarity and in depth instruction. There is a contact link within this website you can use.
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