The effective dates of the Department of Labor’s new 2024 fiduciary advice rule (the “2024 Fiduciary Rule”) and the amendments to Prohibited Transaction Exemptions 84-24, 75-1, 77-4, 80-83, 83-1, 86-128, and 2020-02 (the...more
On April 25, 2024, the U.S. Department of Labor (the “DOL”) finalized a collection of regulatory changes in its ongoing quest to update the definition of a “fiduciary” under ERISA and Section 4975 of the Internal Revenue Code...more
5/17/2024
/ 401k ,
Department of Labor (DOL) ,
Disclosure Requirements ,
Employee Retirement Income Security Act (ERISA) ,
Fiduciary Duty ,
Individual Retirement Account (IRA) ,
Internal Revenue Code (IRC) ,
Investors ,
Policies and Procedures ,
Private Funds ,
Regulatory Requirements ,
Securities and Exchange Commission (SEC)
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
4/9/2024
/ Compliance ,
Criminal Convictions ,
Deferred Prosecution Agreements ,
Department of Labor (DOL) ,
Employee Retirement Income Security Act (ERISA) ,
Exemptions ,
Financial Crimes ,
Investment Management ,
New Amendments ,
Non-Prosecution Agreements ,
Notice Requirements ,
Prohibited Transactions ,
QPAM ,
Shareholders
On January 24, 2024, the U.S. Department of Labor (DOL) published the final rule amending the procedures for filing an individual prohibited transaction exemption application. The amended regulation (the “Procedures”)...more
On November 3, 2023, the U.S. Department of Labor (DOL) proposed a collection of regulatory changes in its ongoing quest to update the definition of a “fiduciary” under ERISA and Section 4975 of the Internal Revenue Code (the...more
If you manage a private investment fund that is subject to Title I of ERISA and is not a feeder fund (an “ERISA Fund”), you should, before December 1, 2023, take the steps described below in order to comply with the DOL’s...more
9/26/2023
/ Beneficiaries ,
Department of Labor (DOL) ,
Employee Retirement Income Security Act (ERISA) ,
Environmental Social & Governance (ESG) ,
Fiduciary Duty ,
Investment Management ,
Pooled Investment Vehicles ,
Private Investment Funds ,
Proxy Voting ,
Retirement Plan ,
Shareholder Rights ,
Trustees
ERISA fiduciaries may consider any factors the fiduciary reasonably determines are relevant to the risk return analysis of an investment, including the economic effects of climate change and other environmental, social, or...more
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
7/29/2022
/ Asset Management ,
Criminal Convictions ,
Department of Labor (DOL) ,
Employee Retirement Income Security Act (ERISA) ,
Exemptions ,
Investment Adviser ,
IRS ,
Management Agreements ,
Proposed Amendments ,
QPAM ,
Record Retention ,
Trade Secrets