The Delinquent Filer Voluntary Compliance Program (DFVCP) is a Department of Labor (DOL) program designed to encourage voluntary compliance with ERISA’s 5500 program. It’s great as a plan sponsor if you forget to file a Form 5500 and pay thousands instead of tens or hundreds of thousands in penalties.
The problem I’ve found with the DFVCP is plan sponsors going through the process and fling the delinquent 5500s yet forgetting the DVCP online application and payment of the program fee. By forgetting the fee and online submission, you would subject yourself to the penalties that the government may lay on you, regardless of your original intent to apply through the DFVCP.
