TP living abroad worked for a foreign company and participated in the company retirement plan. This foreign retirement plan only invests in various US ETFs.

It is my understanding that it is the foreign account not the foreign retirement plan itself that triggers the obligation to file PFIC Form 8621, Form 8938 and FBAR/FinCen 114 reporting (TP met both Form 8938 and FinCen 114 reporting thresholds).

Therefore, TP does not have to file PFIC Form 8621, Form 8938 and FBAR/FinCen 114. Is this correct?

Thank in advance for your time and comment.