"Although certain private funds may be structured to avoid holding 'plan assets,' ... those funds may have agreed in a contract ... to utilize the QPAM Exemption in certain circumstances.... Prior to the effective date [these funds should:] [1] Review all fund documentation including side letters and ISDAs/derivative contracts....[2] Consider DOL notification requirements in light of the September 15, 2024 notification deadline ... [3] Does the fund have sufficient assets under management and capitalization to qualify under the QPAM Exemption in light of the Amendments' requirements? [4] Consider recordkeeping requirements.... [5] Has the fund or any affiliate committed prohibited misconduct under the expanded requirements?"

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