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DOL Clarifies QPAM Exemption's Anti-Criminal Rule (PDF)
Groom Law Group
[Guidance Overview] Dec. 3, 2013 "According to [DOL Advisory Opinion 2013-05A], under a [deferred prosecution agreement (DPA)], the government files a charging document with a court, but requests that the prosecution be deferred to allow the defendant to demonstrate its good conduct over a period of time. If the defendant successfully completes the DPA, the charges may be dismissed and the dismissal is not treated as a conviction. Under these facts, the DOL concluded that the DPAs do not constitute criminal convictions such that the QPAM status of affiliates would be jeopardized." MORE >> |
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