Large plan, never filed, will be late again

the age old question - file an incomplete 5500 without a set of audited Financial Statements, with intent to file amended form later?

plan in question - has never filed 5500, multiple years as a large plan. None will be ready by filing of currently due 5500.

I'm thinking don't file, and file the sum total when ready and submit under dfvc.

Lay out the options for the client and let them decide.

Talk to whoever is spearheading the past filings and see what they suggest.

FWIW, I'd also suggest filing all the past and current filings at the same time with the appropriate audits under DFVC Program as you suggest.

If you file the 5500 without the audited financials, there is a chance that EBSA may bounce your filing. Since your client has not filed Forms 5500 for multiple years, let it get its ducks in a row and file all of the under DFVC for all of the years. The reason is that the penalty for filing late is capped and filing the multiple years simultaneously will likely result in your client hitting the cap under the program. Then there will be no more never filed or late Forms 5500. Now, that would be very nice, don't you agree?