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2022 5500 not filed and without audit report


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We became aware of a non-client plan sponsor who needs a 5500 audit for 2022.  This is not our TPA client.  The plan is bundled with ADP.  The plan sponsor contacted us for a plan audit.  The plan was small for 2021 but went well over 120 as of 01/01/2022.  The 5500 for 202 has not been filed.  ADP prepared the 5500 and I'm guessing takes the position - we posted it on our website and sent an email to the plan sponsor.  I've seen that before with another bundled provider.  And I realize plan sponsors need to be alert to deadlines as they are ultimately responsible.

My question is (and I've seen this before at webinars and didn't pay close attention because I didn't think it would ever apply to us) - should the 5500 be filed now without the audit report?  I'm told the audit will not be completed for a month.  I'd like to get the DFVC penalty paid before the IRS catches the late filing.  I'm surprised it hasn't already.

What do you think about filing the 5500 now without the audit report and amending a month later with the report?

Thank you,


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