@HarishKumar7 , Namaste ji
Please these instructions for the form 3520 below:
Instructions for Form 3520 (Rev. December 2023)
While the particular scheme is not mentioned as one of the "exceptions " to filing requirement ( similar Canadian plans are ), I do not believe you have to report this on form 3520. However, when you do contribute and/or get a distribution, you may have to.
My opinion is that since you are reporting FBAR and the FATCA ( form 8938 ) , you are doing the needful -- filing of 3520 would be duplicative.
If, however, you had a private foreign trust ( grantor or otherwise ) , that you owned. contributed to or received distribution from-- yes you would need to report that.
Is there more I can do for you ?
Namaste ji
pk
