[Bevdeforges]

The streamlined procedure involves filing back returns for 3 years only. It doesn't matter if you haven't filed for longer than that - you'd be "exonerated" for doing those back 3 years plus the present year. Though you also have to do 6 back years of FBARs.

However, if you have not had income exceeding the filing thresholds, you don't have to file income tax returns. Period. And if you are not required to file a return, you are not required to file a form 8938 because it is only filed as part of an income tax return. (Just note that for determining your relevant income, you should include your entire worldwide income - not just US source income. OTOH, the IRS may or may not have any way of knowing your non-US sources of income.)

Don't bother with the certification. Just file the back FBARs and be done with it. You're not part of any program if you didn't have an income tax filing obligation. In the space where it asks for why you're filing late, you just choose the answer "I didn't know I was supposed to." (or however it's worded these days).
Cheers,
Bev

 

[Bevdeforges]

If they are sending "FATCA data" it is only the year end balance of your account. I haven't yet heard of any of the foreign banks sending interest or income information as part of the FATCA disclosures. In fact, in some European countries, the banks specifically advise that they are NOT sending any information regarding the "tax free" accounts (which are not considered tax free by the IRS).
Cheers,
Bev