"[Among other updates, the final amendment] ... [1] removes all doubt about the inclusion of convictions for foreign crimes as ineligibility events under Section I(g), by explicitly referencing the inclusion of foreign crimes that are substantially equivalent to the list of serious domestic crimes that will cause ineligibility for relief under the QPAM Exemption.... [2] expands the circumstances that may lead to ineligibility under a new Prohibited Misconduct category ... [3] provides an automatic, mandatory one-year transition period after ineligibility to help plans and IRAs avoid or minimize possible costs and disruptions when changing QPAMs or adjusting their asset management arrangements based on ineligibility."

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