"The DOL also raised the equity and assets under management thresholds to qualify as a 'qualified professional asset manager' which will be phased in over the next six years. These could prove burdensome for smaller investment managers.... [T]here will be registration and recordkeeping requirements on investment advisers if they wish to rely on the QPAM Exemption in the future.... [T]his could also impact managers relying upon various exemptions under the Investment Advisers Act and the Investment Company Act."

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