No Fund Change Notice

What should be done if a plan sponsor realizes a fund change notice has not been distributed 30 days prior to the change? The change is happening tomorrow and is already in process, it can't be stopped. Should they distribute the notice today even though it's only a day prior? 

Short answer, distribute as soon as possible.  Arguably, they could get hit with a penalty but I have never heard of one being imposed when action was taken to make the disclosure as soon as possible after the deficiency was discovered.