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Late filing DFVCP

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Plan year end was 6-30-23, so 5500-SF was due January 31 2024.
Plan was being audited for prior year, so they neglected to file before Jan 31 due date.
Now its 20 days into February. Can the return be filed electronically, although late, with reasonable cause explanation?
Or [when compared to $250 per day] is it safer just doing DFVCP for $750?  


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If the DFVCP filing is done promptly, it won't be anywhere near $750 - more like $250-$300. Go the the DFVCP calculator and enter the appropriate information. 

IMHO, absolutely file under DFVCP in this situation. The amount is so small that it overrides the hassle of requesting relief, even if you would be "guaranteed" to get that relief.

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Agreed, and from what I had heard, failure to have the audit completed on time is not reasonable cause for late filing.

Kenneth M. Prell, CEBS, ERPA

Vice President, BPAS Actuarial & Pension Services


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