"[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 >>