late 5330 - de minimis - best way to correct

[TPApril]

New small plan client has finally sent in transactional accounting 'in time' for filing 5500. Here's what we've learned:

2009 delinquent contributions were deposited in 2010 with lost earnings of $65. No 5330 filed. No excise tax paid.

2010 delinquent contributions were deposited in 2010 and 2011 with lost earnings of $26 for 2010. No 5330 filed, no excise tax paid, no extension filed.

When calculating excise tax in 2010, does the 2009 portion applying 100% include the unpaid excise tax of 2009? ie 65*100%+65*.15*100% = 74.75?

I understand there is an option to pay excise tax to the trust and allocate to the participants affected. In this case, excise tax will be under $100 each year, and no contributions were deposited over 180 days late. Would this be sufficient, without filing a 5330 or VFCP? I also recall something about filling out 5330's for records, but not submitting.

Much appreciated!