Non-filed large plan Forms 5500

[Guest timcnelson]

I have a potential client who has not filed a Form 5500 for their 401k plan since 2004. They appear to be over the 100 mark each year (133 at end of 2004). I have 2 questions:

1) Can they use the DFVCP for 2005-2010 Forms 5500

2) Since all years appear to be "large" plans, does an audit have to been done for each year and an auditors opinion attached to each Form 5500.

[ETA Consulting LLC]

Yes and Yes.