Not totally clear on the rules of how to submit a DFVC filing with multiple 5500s that have not been previously filed. If plan sponsor/administrator signs the form, can they send all forms back to tpa's office along with the penalty check and then tpa submits to DOL, even though tpa has no certification? I dont see why there would be a problem with this, but just never know. Im trying to understand what it means to represent a client to the DOL/IRS.

The DFVC filer is the plan administrator, the one that is responsible for having prepared and filed timely f5500s. The tpa may mail off the f5500s and a DFVC application signed by the sponsor/administrator. If the tpa is to be the one that interacts with DFVC personnel, on behalf of the plan administrator, the tpa will need to be authorized in writing as the agent of the plan administrator for this purpose.

John -- What's a DFVC Progam application? All I know to do is file the Form 5500 and then also send a copy, with check, to the DOL's DFVC Program address--both of which I do for the client with a cover letter.

The cover letter and those items are it.