"Late" Form 5500 for MTIA

We have a company that files a 5500 for the Master Trust and then two additional 5500 for the 401k plansa (3 total 5500). The  401k plan 5500's were filed for extension. The MTIA 5500 was not extended. Is there a late fee for the MTIA? Can we use DFVCP for MTIA? Seen conflicting information and wanted to confirm. Thanks!

An MTIA is a DFE filing and is normally due 9 !/2 months after the end of the DFE year that ended in 2018.  Check the instructions for When to File.

The instructions for Penalties reference plan sponsors and plan administrators and nothing about DFEs.

If you are filing for a calendar year DFE, you have until 9/15 to file the DFE filing.

The 5500 instructions indicate that the filing deadline for Master Trusts are within 9 1/2 months of the end of the plan year - they are not eligible for a Form 5558 extension.  If your plan year was 1/1/18 -  12/31/18, that would make the 9 1/2 month deadline October 15, 2019 (that's a full 9 months plus the 15th day that goes into October).

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