"The unknown is how quickly the DOL sends a delinquency notice, ending eligibility to use DFVCP and subjecting the plan sponsor to those big daily penalties.... [A]lthough the IRS is often the faster agency (sometimes sending notices within only a couple months), the DOL can take 4 to 6 months or longer.... The assumed 'advantage' of submitting a timely but incomplete form and amending later is that it avoids the daily penalties. ... both the IRS and DOL tend to respond more quickly to deficient Forms 5500 than delinquent ones. And if the deficiency is due to something obvious (like the plan auditor's report) being omitted, the agencies tend to be heavier-handed. "  MORE >>