A client was notified by IRS that no 2011 and 2012 Forms 5500 had been filed for their 401(k) Plan. Due to an employee change within the client's company, the 5500s were not filed, although they had been prepared. Upon receipt of the IRS notice, client filed the delinquent 5500s. Then client calls us asking what can be done about IRS penalties assessed. Is it too late to use the DFVC Program to avoid the IRS penalties? Will the program now only relieve them of DOL penalties?