DFVCP Fee

[Keith Lowery]

Is there a DFVCP fee for a late 5500 filing that has no assets or lives ?

I have a PEP with a Dec 2022 effective date.  However, no plans joined the PEP until 2023.

 

Thanks!

[RatherBeGolfing]

22 hours ago, Keith Lowery said:

Is there a DFVCP fee for a late 5500 filing that has no assets or lives ?

If you are required to file and file late, you either pay the penalty or the DFVCP user fee. 

The penalty for a small plan is $10 per day capped at $750, for a large plan its $10 per day capped at $2,000.  Participants don't matter for the $10 per day, just the cap.

For purposes of the calculator, I think you have to "trick" it by entering 1 participant instead of 0.  It needs the count to decide if the cap is $750 or $2,000.

[Gina Alsdorf]

Just a note not a suggestion:  You do have the option of requesting penalty relief due to reasonable cause as an alternative to submitting via DFVCP.  It's a facts and circumstances test whether or not you would be eligible for relief.   

[thepensionmaven]

Penalty takes too much time and headaches and is up to the reviewer. DFVC is mostly automatic, gratifying and isn't your time worth at least an additional $750?