We have a client who missed the wife's RMD's for both 2017 and 2018. They filed both year's returns on a timely basis and there are no other changes for either year. I believe we can file 5329's only without a 1040X for each year including a penalty waiver explanation , using each year's version of the Form 5329. The instructions are unclear as to whether we file a 1040X if the returns are already correctly filed and no other changes anticipated. Seems to me the Form 5329 can be as stand alone form as long as it is signed by the account holder and includes a current address. Do I have it right?