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QPAM Exemption Amendment: Key Takeaways and Action Steps for Advisors and Other Stakeholders
K&L Gates 
[Guidance Overview] Apr. 30, 2024 "The Amendment will make the QPAM Exemption more difficult to rely upon, and, as a result, fewer asset managers may be able to qualify as QPAMs ... A one-time notice to DOL may not be a difficult condition, but overlooking this condition or failing to update the notice in a timely manner when an entity changes its name could result in the QPAM Exemption not being available. The notice requirement effectively eliminates the ability of advisers to rely on the QPAM exemption retroactively[.]" |
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