"The Amendment requires that investment advisers operating as QPAMs in reliance on the Exemption maintain records for six years ... demonstrating compliance with the Exemption. These records must be available for examination by the DOL as well as plan fiduciaries and plan participants with respect to investing plans (Plans) ... This checklist is intended to provide a framework for analyzing compliance with the recordkeeping requirement with respect to transactions to which the general conditions of Part I of the Exemption apply."

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