I thought looking at the amount of penalty might shed some light. I have notices for two different 8955-SSAs filed the same day. Plan X 16 A’s 23 D’s $10,560 penalty. Plan Y 2 A’s 1 D $660 penalty. If it was just D’s being penalized you would think the penalty for each divided by the D’s would be the same. But then I cannot find any simple factor that reconciles the two penalty amounts.