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DOL Proposes Significant Changes to QPAM Exemption
Dechert LLP
[Guidance Overview] Aug. 4, 2022 "The proposal would generally: [1] Substantially expand disqualification events.... [2] Impose a one-year winding-down period for the QPAM -- triggered on covered conviction or prohibited misconduct.... [3] Require written assurances and indemnities to plan clients.... [4] Mandate QPAM registration with the DOL for national database.... [5] Impose recordkeeping requirements on QPAM exemption compliance and compel access by regulators, plans and participants and beneficiaries.... [6] Offer new color on QPAM as required decision-maker.... [7] Increase client assets under management and shareholder equity thresholds." MORE >> |
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