8955-SSA DVFC?

Interestingly, never had a late 8955-SSA alongside late 5500's filed under DFVC.

Plan in question never filed a 5500 for 3 years.  Last 2 years of that there were 8955-SSA's that needed to be filed. 

File them late? Or file one consolidated 8955-SSA along with current year?

The IRS provided guidance in Notice 2014-35.  This was when the Schedule SSA was replaced by Form 8955-SSA and the filing were made through EFAST2, and yes, that was 10 years ago.

You will need to file a form for each year that needed to be filed.

If the 8955-SSA is late for a year, there is relief from penalties if the 8955-SSA is filed within 30 days after the 5500 under the DFVCP for that year.  The late 8955-SSA must be filed on paper and sent to the IRS.  On the 8955-SSA, check the special extension box in Part I Box C and enter DFVC for the description.

Send the forms, if using mail to:

Department of the Treasury
Internal Revenue Service Center
Ogden, UT 84201-0024

If using a private delivery service, send to:
Internal Revenue Submission Processing Center
1973 Rulon White Blvd
Ogden, UT 84201

Thanks Paul!

The Notice is brief.

My next question is: File them as snapshots in time, or can we exclude participants who would be filed as both 'A' and 'D' during the period?

I agree that would seem to make sense, but why bother risking some agent deciding otherwise?

If you are preparing the filing using software that supports 8955-SSA filings, the software very likely imports the participant data from a spreadsheet.  If should be very easy to copy data from one year to another, and report an employee as an 'A' in one year and a 'D' in a subsequent year.