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Now that delinquent 5500 forms (even for pre-99 years) are filed with the DOL rather than the IRS, what will your procedures be when filing a delinquent 5500 form?

Will you always use the DOL's Delinquent Filers Voluntary Compliance Program (DFVC)? Why or why not?

Will you send a letter of explanation with the delinquent filing?

Will you send a request for waiving fees or penalties with the delinquent filing?

Will your procedures change from whatever delinquent filing procedures you used when filing with the IRS?

Do the answers depend on the reason the filing is delinquent?

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