5500 has not been filed

[PainPA]

If a 5500 has never been filed, at least cannot be seen on freeERISA and all the other public websites, how far do you have to go back with the filings?

I understand that the Delinquent Filer Voluntary Compliance Program caps the penalty at a per plan max of $4,000.00 for a large plan. How far do you have to go back?

I have heard that you would only have to file 3 years worth (2004, 2005 & 2006). Is there any documented evidence of this or is it obtained through a Private Letter Ruling?

[WDIK]

You can find some good advice (though not a definite solution) at the link below. You will need scroll down.

http://www.form5500help.com/ItsOfficialArticle.html

[Kevin C]

There is information on the DOL website about the program. From the Q&A's it looks like the program applies at least back to the 1988 year filings. From what I recall, the penalty relief only applies to the years included in the filing.

http://www.dol.gov/ebsa/Newsroom/0302fact_sheet.html

http://www.dol.gov/ebsa/FAQs/faq_DFVC.html