File under DFVCP without the required audit attached?

Is it possible to file under DFVCP without the required auditor report attached?  5500 was already filed and accepted w/out audit report.  IRS has issued penalty notice but due to some very unique circumstances including a company merger, audit is just in the initial stages but IRS notice is coming up on 30 days.  Would it be ok to have the plan sponsor/TPA refile the same 5500 (w/out audit) under DFVCP and then amend the 5500 again once the audit is completed.  

The end of this thread addresses a similar question. Once you file an incomplete filing you are deficient, not delinquent (I confirmed this when I spoke with the Office of the Chief Accountant years ago); therefore, DFVCP is not an option. 

I'm not sure it's true that filing an incomplete 5500 precludes DFVCP.  The IRS Website below certainly makes it sound like Incomplete = Late.  "Late" can be fixed with DFVCP until DOL sends a Notice of Intent to Assess a Penalty (See DOL DFVCP Fact Sheet.)

https://www.irs.gov/retirement-plans/irs-filing-notices-for-form-5500-5558-or-5500ez

Below is the basis for my comment, This comes from the Federal Register, 2013 DFVCP update. DFVCP does not extend relief to a plan sponsor for a deficient/incomplete filing. I may be interpreting this incorrectly. 

https://www.govinfo.gov/content/pkg/FR-2013-01-29/pdf/2013-01616.pdf

Section 2—Scope, Eligibility and Effective Date .01 Scope. The DFVC Program described in this Notice provides relief from assessment of civil penalties under section 502(c)(2) of ERISA applicable to plan administrators who fail or refuse to file timely annual reports. Relief under this Program does not extend to penalties that may be assessed for annual reports that are determined by the Department of Labor (Department) to be incomplete or otherwise deficient. (emphasis is mine)

This answers the OP question which comes from Section 3 in the above link:

(a) Requirement To File The Delinquent Annual Return/Report. The plan administrator must file in accordance with this section a complete Form 5500 Series annual return/report, including any required schedules and attachments, for each plan year for which the plan administrator is seeking relief under this DFVC Program.