Client (US person living in UK) has had a retirement account for ~30 years with an employer for which she was the contributor.
She left the company several years ago and took a lump sum for most of it, but a small amount still exists in the account.
FBAR and 8938 requirements are obvious - but does this also mean it is treated as a foreign trust and she had been delinquent in filing 3520 for all of these years?