Small Pension Plan Audit Waiver Exemption Blown - what happens?

[Benefits to all]

I have a client who has been checking the box for the exemption for small pension plans under Reg. 2520.104-46 in order to waive the annual audit requirement. However, the client has not been providing the requisite information to the participants as called for by the regulation. Does that mean the exemption is blown and we would have to go back and audit for the past decade? Any insight would be appreciated.