Virtual Currency Regulations: Key Insights for the Payments Industry — Payments Pros – The Payments Law Podcast
Protection of Critical Infrastructure via LIPA and ICTS
Compliance Perspectives: Sanctions, Data and Vetting Third Parties
ITAR for Facility Security Officers
Podcast - Credit Funds: How Managers Can Avoid and Mitigate ERISA Conflicts
Under the Supreme Court’s recent decision in Cunningham v. Cornell University, No. 23-1007 (April 17, 2025), plaintiffs asserting that ERISA plan administrators engaged in prohibited transactions under ERISA Section 406 are...more
As an asset manager, you may be familiar with the regulatory issues that come into play when a fund permits investments from “benefit plan investors,” which generally include certain employee benefit plans subject to the...more
Earlier this year, the Department of Labor (DOL) updated the prohibited transaction exemption for Qualified Professional Asset Managers, often referred to as the “QPAM exemption.” Included in the update is a new requirement...more
The U.S. Department of Labor’s (DOL) latest attempt to redefine who/what a fiduciary is for purposes of the Employee Retirement Income Security Act of 1974, as amended (ERISA), has been stayed by two U.S. district courts on...more
The DOL’s fiduciary regulation was scheduled to become effective this September 23. The exemptions were scheduled to become partially effective this September 23 and fully effective September 23, 2025....more
The Department of Labor’s final regulation defining fiduciary status for investment advice to retirement investors will be effective this September 23. Where a fiduciary recommendation results in additional compensation for...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
The Department of Labor (DOL) recently released the Retirement Security Rule - yet another iteration of its updated fiduciary rule that has been kicking around the agency for over a decade....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
On April 23, the US Department of Labor (DOL) released a final rule significantly expanding the definition of who qualifies as a fiduciary under the Employee Retirement Income Security Act (ERISA) (the Retirement Security...more
For the second time in a decade, the Department of Labor (DOL) attempted to expand the reach (and requirements) of the Employee Retirement Income Security Act of 1974 (ERISA). On April 23, 2024, DOL succeeded and announced...more
What has changed with the U.S. Department of Labor’s (DOL) final regulations and certain prohibited transaction exemptions (PTEs)? Is it really that bad even for plan sponsors, as we hear from the many critics of the DOL’s...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 25, 2024, the Department of Labor published its final regulation on fiduciary advice, and the related exemptions, in the Federal Register. The regulation defines fiduciary investment advice and the exemptions provide...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 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
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
On April 3, 2024, the Department of Labor (DOL) published final changes to Prohibited Transaction Class Exemption 84-14, commonly known as the “QPAM Exemption”. The changes make reliance on the QPAM Exemption more burdensome...more
The U.S. Department of Labor has released its package of proposed changes to the regulation defining fiduciary advice and to the exemptions for conflicts and compensation for investment recommendations to retirement plans,...more
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
The new “retirement security rule” package, issued by the U.S. Department of Labor (the “DOL”) on October 31, 2023, is the latest chapter in an almost 15-year effort by the DOL to amend the five-part test in its 1975...more
The US Department of Labor has released its package of proposed changes to the regulation defining nondiscretionary fiduciary advice and to the exemptions for conflicts and compensation for investment recommendations to...more
UPDATE: On August 8, I posted this blog article in contemplation of the DOL sending a new fiduciary proposal package to the Office of Management & Budget (OMB) in the White House. One month later, to the day, the receipt of...more