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Posted

There is a new audit client that did not attach the accountant's review of the 5500 upon filing.  Would anyone be able to cite the potential ramifications and penalties for an error like this?  I believe this would have to be corrected through VCP or DFVC, but I'm pretty sure the penalty would be under DOL/IRS discretion.

Posted

Just file the amended 5500 ASAP attaching the auditor's report.

From Form 5500 instruction – “If the required IQPA’s report is not attached to the Form 5500, the filing is subject to rejection as incomplete and penalties may be assessed.“

From DOL EFAST FAQ – “Q25: Will EFAST2 receive my filing if I do not attach the IQPA report to my Form 5500 annual return/report? EFAST2 will receive your filing, but the filing is incomplete without the required IQPA report. An incomplete filing may be subject to further review, correspondence, rejection, and civil penalties. Please note Schedule H, line 3 specifically asks for information regarding the plan’s IQPA report. If you do not submit the required IQPA report, you must still correctly answer these questions. If you have to file Form 5500 without the required IQPA report, correct that error as soon as possible.

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