C Corporation client didn't file 2017 Form 5500 and now the penalty is nearly 12K.

I have read about the VFCP. Late filing, or non-filing, of Form 5500 is not a listed fiduciary violation. Is my client ineligible to apply for the DFVCP?  Is there a provision that would allow them to participate?

The benefit of the program is that paying the minimum $750 DOL penalty removes the big penalty. I hope this is true.

As policy, it would be right to allow a late filer the same option to reduce a big penalty as bigger fiduciary violators get.

EDIT #1: The plan sponsor also didn't file 2018 and 2019 and is subject to penalties of 2k and 70K, respectively.  That is right - SEVENTY THOUSAND.  

I know that the First - Time Abatement is an option but this can be used once. So, using it to delete 12K and leaving the 70K open isn't a smart plan.

#2 If you think one of the IRS debt relief or tax defense firms, I'd like your opinion.