DFVC Penalty Calculator - Showing Late Filing That's Not Late?

[notapensiongeek]

I brought up the DFVC Penalty Calculator for a plan with a late filing in 2024.  But when the list of late filings in EFAST appeared, it showed two years, not just the 2024 filing.

The other year, 12/31/2022, was filed on 10/16/2023 through EFAST.  Since 10/15/2023 fell on a Sunday, the filing date of 10/16/2023 is timely. An extension was filed before 7/31/2023, and the extension box is clearly checked on the form.

Am I missing something, or does it appear that the 2022 filing should not be considered late?  Should they pay the penalty on 2022 as well, even though it's not late?

[Peter Gulia]

Might it be as simple as EBSA’s software was not told to apply the holidays tolerance?

Some plan administrators might incur an incremental DFVC expense because that expense might be less than an expense to explain that the report is not delinquent. Is $750 less expensive than one hour of a professional’s time? Or less expensive than a minimum fee for a new task?

I’m curious: Does the DFVC require a user to state that the report is delinquent? Or may a user get DFVC protection without saying that the report is delinquent?