News & Analysis as of

Criminal Convictions QPAM

Morrison & Foerster LLP

Amendment To QPAM Exemption

The Department of Labor (DOL) recently issued a final amendment (“Final Amendment”) to Prohibited Transaction Exemption (PTE) 84-14, which is otherwise known as the “QPAM Exemption.” The QPAM Exemption is a prohibited...more

Latham & Watkins LLP

Raising the Bar: DOL’s Amendment Sets Higher Standards for QPAM Qualification

Latham & Watkins LLP on

The DOL’s final amendment to the QPAM Exemption sets forth more rigorous compliance requirements and expands the circumstances of ineligibility, potentially affecting the operations and compliance procedures of investment...more

Proskauer - Employee Benefits & Executive...

DOL Unveils Final Amendment to QPAM Exemption

On April 3, 2024, the U.S. Department of Labor (the “DOL”) published in the federal register a final amendment to Prohibited Transaction Class Exemption 84-14 (the “QPAM Exemption”) that makes considerable changes to the...more

Akin Gump Strauss Hauer & Feld LLP

DOL Issues Final Amendment to the QPAM Exemption

On April 2, 2024, the U.S. Department of Labor (DOL) announced its final amendment to prohibited transaction class exemption 84-14 (the QPAM Exemption). The QPAM Exemption is a broad-based class exemption relied upon by many...more

Dechert LLP

Not Quite QPAMDEMONIUM: DOL Issues Final Changes to the QPAM Exemption

Dechert LLP on

On April 3, 2024, the Department of Labor (the “DOL”) issued its final amendment (“Final Amendment”) to Prohibited Transaction Class Exemption 84-14, commonly referred to as the “QPAM Exemption”. Generally, the QPAM...more

Seward & Kissel LLP

DOL Finalizes Amendments to the QPAM Exemption – All QPAMs Must Take Action

Seward & Kissel LLP on

On April 3, 2024, the U.S. Department of Labor (DOL) published significant modifications to Prohibited Transaction Class Exemption 84-14 (the QPAM Exemption). The amendment becomes effective on June 17, 2024; however, certain...more

King & Spalding

Department of Labor Finalizes Changes to QPAM Exemption

King & Spalding on

Investment managers who manage private employee benefit plan and individual retirement account (collectively, “Plan”) assets have long relied on Prohibited Transaction Class Exemption 84-14 (commonly referred to as the “QPAM...more

Proskauer - Employee Benefits & Executive...

DOL Proposes Significant Changes to the QPAM Exemption – What You Need to Know

On July 27, 2022, the U.S. Department of Labor (the “DOL”) issued notice of a proposed amendment (the “Proposed Amendment”) to Prohibited Transaction Class Exemption 84-14 (which is commonly referred to as the “QPAM...more

Eversheds Sutherland (US) LLP

DOL’s proposed QPAM amendments may amount to an effective revocation of the exemption

In the guise of clarifications relating to criminal convictions and misconduct, the Department of Labor (DOL) has proposed major amendments to Prohibited Transaction Exemption (PTE) 84-14, also known as the QPAM exemption...more

Seward & Kissel LLP

DOL Proposes an Amendment to the QPAM Exemption

Seward & Kissel LLP on

On July 27, 2022 the U.S. Department of Labor (DOL) proposed significant modifications to Prohibited Transaction Class Exemption 84-14 (the QPAM Exemption). The DOL will accept written comments and requests for public...more

Groom Law Group, Chartered

DOL Opines That Foreign Criminal Convictions Are Not Fatal Under QPAM Exemption

On November 3, 2020, the Department of Labor’s Office of the Solicitor of Labor (the “DOL”) issued to the Securities Industry and Financial Markets Association (“SIFMA”) an opinion letter (the “Solicitor’s Letter”) in...more

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