Form 8955 Deliquent filing

Has anyone had to file a late Form 8955.  We have a new client and this was not filed for 2016.  It appears that DFVCP- is available and I am researching further.  There is no formal correction program but I saw instructions from the IRS saying file under DFVCP which I suppose means re-filing the 5500 and paying the penalty. 

Does anyone have experience with this?

Thank you,

Tom

I once had a client where both the 5500 and 8955 was late we filed the 5500 under DFVCP and followed the instructions for the 8955 and it went smoothly.  I have never re-filed the 5500 and then the 8955. 

I do know the IRS does check to see if you file the 8955 if an auditor comes out to look at the 5500.  However, since it is possible to not have an 8955 due for any year they can't know if the form wasn't filed because it was missed or there was no one to report.  So there is always opens up the idea of playing the audit lottery and report the missed people on the next 8955 and call it quits.  I guess there is a chance that will leave the client open to a fine but if you can show they are on the next form some auditors might take the no harm no foul position. 

It is known costs vs unknown level of higher cost but also no cost is possible out come. 

I would be concerned about reporting DVPs on a later form as that would give an auditor ammunition.  I would instead file the 8955-SSA as soon as I knew who should have been reported.  This will at least show good faith on the Plan Sponsor's part.