DFVCP instructions are unclear

[Guest NC Taxman]

I have a 501©(3) client with a small 403(b) plan (3 qualifying participants) that needs to file for the current year, plus the preceding 4 years (total of 5 years).

I've read through the 5500 instructions, the EFAST2 FAQs, the DFVCP FAQs, the DOL website and have browsed through this forum as well and haven't been able to find in a single location the exact steps to properly file under the DFVCP. This is what I have assembled through various sources and am looking for confirmation or correction:

1. Prepare all 5 years on the current-year 5500 form with the appropriate corresponding plan year in Part I.

2. Mark the box for "filing under DFVC program" on all 5 years' returns.

3. Electronically file all 5 years separately with EBSA through the EFAST2 system.

4. Separately mail all 5 years' returns to DFVCP with "501©(3)" clearly marked on the upper-right corner of each return to qualify for the $750 total fee limit. Include a brief cover sheet explaining the returns are being filed under the DFVCP and have already or will be filed with EBSA through the EFAST2 system. Include payment and mail the returns, payment and cover letter to:

DFVC Program - DOL

PO Box 70933

Charlotte, NC 28272-0933

Is this the correct process? Is there something I'm missing? Should I mail paper forms to DFVC first, then e-file with EBSA? or vice-versa?

Any help is greatly appreciated. Time is of the essence, as the current-year is due 4/15/11. Thanks in advance.