Preparing for Changes to the QPAM Exemption

Lowenstein Sandler

Megan Monson, Andrew E. Graw, Taryn E. Cannataro of Lowenstein’s Employee Benefits & Executive Compensation group discuss with partner Marie DeFalco, Co-Chair of the firm’s Investment Management group, the significance of the QPAM exemption from ERISA prohibitions on transactions with a party in interest for investment advisers. The group explains current and possible new requirements for qualifying for the QPAM exemption; registration and recordkeeping rules; the potential impact of raising the required total AUM; and how the lack of a lack of a “grandfathering” period can prove a challenge for investment advisers.

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