On April 2, 2024, the Department of Labor (the “DOL”) finalized its amendment to the Qualified Professional Asset Manager (“QPAM”) prohibited transaction exemption (the “QPAM Exemption”). Among the changes made to the QPAM...more
The amendments to the QPAM Exemption include a September 15, 2024 notification deadline that will apply to many asset managers. This blog post includes a brief summary of the US Department of Labor’s (DOL’s) recent technical...more
On April 2, 2024, the US Department of Labor (DOL) issued an amendment establishing new rules (New QPAM Rules) for what is commonly referred to as the "QPAM Exemption." The QPAM Exemption is the main exemption relied upon by...more
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
On April 2, 2024, the Department of Labor (“DOL”) released an amendment to Prohibited Transaction Exemption 84-14 (the “QPAM Exemption”). One requirement of the new rule is that managers must notify DOL via email...more
The US Department of Labor (DOL) published final amendments to Prohibited Transaction Class Exemption 84-14, the so-called “QPAM Exemption,” in the Federal Register on April 3, 2024. The amendments are anticipated to affect...more
Executive Summary - Many investment advisers and other financial institutions rely on the Department of Labor’s QPAM Exemption when providing services to, and transacting with, employer-sponsored retirement plans, individual...more
On April 3, 2024, the U.S. Department of Labor (DOL) published a final amendment to Prohibited Transaction Class Exemption 84-14. The amendment will become effective June 17, 2024....more
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
On April 3, 2024, the Department of Labor (the "DOL") published its final amendment (the "Amendment") to Prohibited Transaction Class Exemption 84-14 (the "QPAM Exemption"), which permits certain otherwise-prohibited...more
Our Employee Benefits & Executive Compensation and Investment Funds Teams break down the increased compliance requirements – and compliance costs – qualified professional asset managers (QPAMs) face under the Department of...more
The US Department of Labor (DOL) final amendment to Prohibited Transaction Class Exemption 84-14, the so-called QPAM Exemption that is commonly relied upon by investment managers for ERISA-governed employee benefit plans and...more
On April 3, 2024, the US Department of Labor (“DOL”) published the final amendment (“Amendment”) to Prohibited Transaction Class Exemption 84-14, otherwise known as the “QPAM Exemption” (“Exemption”).1 The Exemption is...more
The Department of Labor (“DOL”) issued the final amendment to the qualified professional asset manager (“QPAM”) prohibited transaction class exemption on April 3, 2024, with an effective date 75 days later (i.e., June 17,...more
On April 2, 2024, the Department of Labor (“DOL” or “Department”) released an amendment (the “Amendment”) to Prohibited Transaction Exemption 84-14 (the “QPAM Exemption” or “Exemption”). The changes were proposed by DOL in...more
While the Department of Labor’s environmental, social, and governance rule garnered a lot of attention in 2022, there are two other developments simmering that could have significant implications for ERISA plans and financial...more
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
On July 26, the United States Department of Labor (“DOL”) issued proposed amendments to Prohibited Transaction Class Exemption 84-14, the so-called “QPAM Exemption.” The QPAM Exemption is an important prohibited transaction...more
The Department of Labor (“DOL”) recently proposed an amendment (the “Proposed Amendment”) to Prohibited Transaction Class Exemption 84-14 (the “QPAM Exemption”). The Proposed Amendment would...more
The Department of Labor (the “DOL”) on July 27, 2022, on its own initiative, proposed changes to Prohibited Transaction Class Exemption (“PTCE”) 84-14, commonly referred to as the “QPAM Exemption” (the “Proposal”). In general...more
On July 26, 2022, the U.S. Department of Labor (the “Department”) issued a proposal to amend prohibited transaction class exemption 84-14 (the “QPAM Exemption”) under ERISA. The QPAM Exemption currently allows a plan’s...more
The US Department of Labor (DOL) published in the July 27, 2022, Federal Register a number of proposed changes to Prohibited Transaction Class Exemption (PTE) 84-14, the so-called “QPAM Exemption.” Investment managers of US...more
On June 26, 2022, the U.S. Department of Labor (DOL) announced a proposed amendment to the prohibited transaction class exemption 84-14 (the “QPAM Exemption”). The QPAM Exemption is a broad-based class exemption relied upon...more
On July 27, 2022, the Department of Labor (DOL) proposed a set of amendments to Prohibited Transaction Class Exemption 84-14, the so-called “QPAM Exemption,” which permits an investment fund holding assets of ERISA plans and...more
On November 3, 2020, the U.S. Department of Labor’s Office of the Solicitor of Labor (the “DOL”) issued an opinion letter (the “2020 Letter”) to the Securities Industry and Financial Markets Association (“SIFMA”) stating that...more