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American Retirement Association Comment Letter to EBSA on Proposed Amendment to the QPAM Exemption (PDF)
American Retirement Association [ARA] 
[Opinion] Oct. 13, 2022 "[ARA recommends] that the Department: [1] Modify the exclusive authority condition of the proposed amendment to Section I(c) of the QPAM Exemption so as not to preclude routine business interactions. [2] Modify the conditions of the one-year winding down period of proposed new Section I(j) so as not to preclude new transactions in existing accounts which are required for a prudent winding down process. [3] Provide at least 18 months for QPAMs, plan sponsors, and other parties-in-interest to come into compliance with the conditions of an amended QPAM Exemption." MORE >> |
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