DFVC question

[goldtpa]

Have picked up a new client, self employed doctor. Plan has been in exsistence since 1992. Doc never filed a 5500 because he thought if the assets were under 100,000 he didn't have to file.

Problem is that he has other employees. One part-timer who works less than 800 hours a week. And a full time nurse. Everything else, like plan documents, seem to be in order. We have recalculated the plan's assets to give the nurse a benefit.

I think that we would have to go to thru DVFC. How far back can you file 5500s?

[Guest CAM223]

We went back to 1989 last year for two plans. I don't think that there is a definite year to go back to.

[goldtpa]

Thanks. One more question. Did you charge per return or charge by the hour?

[Kirk Maldonado]

There is a definite cutoff in how far you have to go back. Before a specific date (which I can't recall) the DOL lacked statutory authority to impose a monetary sanction for the failure to file.

[SoCalActuary]

We have done a few of these, and we figured our charges both ways: What is the normal annual charge for each return, vs. how many hours will it take.

What was of concern to us after we started was the extra time not anticipated in the filings, most notably the extra time for finding trust accounting and the extra time negotiating with reluctant gov't workers.

However, it's your business, so negotiate a fee that works for you.

[Guest CAM223]

Refer to the Department of Labor website--EBSA. Most of your questions can be answered there--the website also has phone numbers to call. We have called them as well as the IRS on issues relating to late 5500's and have had excellent

advice.