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Prohibited Transactions Exemptions Investment Management

Winstead PC

The QPAM Exemption - Key Takeaways for Fund Managers with Benefit Plan Investors

Winstead PC on

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

Faegre Drinker Biddle & Reath LLP

The New Fiduciary Rule (44): The Regulation and Exemptions are Stayed (4)—What Remains?

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

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

Bricker Graydon LLP

DOL Fiduciary Investment Advice - We Have Tread This Road Before, Has Anything Changed for Advisors?

Bricker Graydon LLP on

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

Faegre Drinker Biddle & Reath LLP

The New Fiduciary Rule (32): The DOL’s Final PTE 2020-02

On April 25, 2024, the Department of Labor published its final regulation defining fiduciary status for investment advice and the related exemptions—PTE 2020-02 and 84-24. The exemptions provide relief from prohibited...more

K&L Gates LLP

QPAM Exemption Amendment—Key Takeaways and Action Steps for Advisors and Other Stakeholders

K&L Gates LLP on

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

Foley Hoag LLP

QPAM Amendment – Action Required by Investment Managers

Foley Hoag LLP on

The U.S. Department of Labor (“DOL”) has amended the qualified professional asset manager (“QPAM”) class prohibited transaction exemption 84-14 (“QPAM Exemption”), effective as of June 17, 2024 (“QPAM Amendment”)....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

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

Faegre Drinker Biddle & Reath LLP

The New Fiduciary Rule (22): Can Wholesalers Become Fiduciaries

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

Proskauer Rose LLP

A Guide to the DOL’s New Investment Advice Fiduciary Rule Proposal – What Investment Advisers and Managers Need to Know

Proskauer Rose LLP on

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

Faegre Drinker Biddle & Reath LLP

Best Interest Standard of Care for Advisors #83: Compliance with PTE 2020-02: Enforcement of the Exemption

This series focuses on the DOL’s new fiduciary “rule”, which was effective on February 16. This, and the next several, articles look at the Frequently Asked Questions (FAQs) issued by the DOL to explain the fiduciary...more

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