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DOL Proposes 'Update' to QPAM Exemption
The Wagner Law Group 
[Guidance Overview] Aug. 9, 2022 "Many provisions go beyond just addressing bad actors, foreign convictions and exemption ineligibility ... These higher thresholds, and the burden of annual required updates, will be difficult to achieve for smaller QPAMs. New recordkeeping requirements add significantly to the burden of compliance, without any significant justification.... Clarification is needed on the exemption when it is used by a QPAM for hiring service providers[.]" |
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