A company established a SIMPLE IRA in 2004 and signed a SIMPLE IRA Adoption Agreement with a mutual fund company. The language in the Adoption Agreement names the mutual fund company as the designated financial institution (DFI) for ongoing contributions. In 2019, two of the owners transferred their existing SIMPLE IRAs to new SIMPLE IRAs with a different financial institution. The ongoing contributions for these two individuals were also sent to this different institution, which is not the DFI. There was no change to the original Adoption Agreement with the original mutual fund company and a new Form 5304 was not signed.

Is there any type of correction that needs to be made in a situation like this where the company was not sending ongoing contributions to the DFI? The company does intend to either change to a Form 5304 or select a new DFI, but knows it cannot be done until 2022 (with proper notice). Thanks.