Investment Change Notice Failure

Have a client that failed to give a 30 day fund change notice to participants.  From what I can tell, there is not an actual penalty prescribed by the DOL other than a plan sponsor could be held liable for a fiduciary breach.  Based on this I was going to advise them to just give out the updated notice ASAP.  Anything I am missing?  

I don't think so. It's not too dissimilar from failing to distribute a SH notice (excluding the breach that you mention).

Any chance the notice was posted on the RK site?