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It doesn't look like anyone else is going to answer, so I'll give it a try. The 404(a)(5) annual participant fee disclosure is an ERISA requirement, so I'm not surprised it isn't addressed in the IRS EPCRS program. I don't see it listed as one of the issues that can be corrected under the DOL Voluntary Fiduciary Correction Program (VFCP). A late notice is considered a fiduciary breach, but there doesn't seem to be anything listing a specific penalty. I don't think there is anything the client can do except to send the notices out asap.