Wrong EIN on 5500

[Tinman]

Detail:  Traditional 401(k) plan that's been in effect since 2006.  For the first year, the plan was filed using the correct EIN.  The following year (and each year since) the plan was filed using an incorrect EIN (off by one number).  They even received a delinquent filing notice from the IRS back in 2007 due to the incorrect EIN situation.

What would be the correction here?  Would the plan need to:

1)  Amend all 5500s back to 2007?  If yes, how would the 2017 filing be handled?  Would they need to indicate a "change" in Q. 4 on the Form 5500, indicating a change in the name and/or EIN of the plan sponsor?  (4 If the name and/or EIN of the plan sponsor or the plan name has changed since the last return/report filed for this plan, enter the plan sponsor’s name, EIN, the plan name and the plan number from the last return/report:)

2)  Just indicate the "change" in Q. 4 and move forward, not amending any past filings?

3)  Any reason to use DFVCP in this situation?

Any other thoughts/suggestions would be greatly appreciated!!

[Madison71]

Good morning.  I would change prospectively by indicating the change in Q.4 on the Form 5500 and be done with it.  I would not amend past filings nor use DFVCP for this situation. 

[RatherBeGolfing]

26 minutes ago, Tinman said:

They even received a delinquent filing notice from the IRS back in 2007 due to the incorrect EIN situation.

2007 or 2017?  

[Tinman]

2007