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Proposed QPAM Amendment Would Expand Criminal Disqualification Rules and Add Contractual Protections for Plans
Debevoise & Plimpton LLP [Guidance Overview] Aug. 15, 2022 "[T]he amendment would codify the DOL's interpretation that foreign crimes substantially equivalent to the enumerated U.S. offenses result in disqualification. The amendment would also add categories, short of actual crimes, permitting the DOL to strip a manager of QPAM status. The Amendment would require QPAM management agreements to indemnify plan clients against losses resulting from the QPAM's disqualification, and impose a mandatory one-year winding down period following disqualification to help plans mitigate disruptions from changing advisors." |
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