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Retirement Plans Newsletter

BULLETIN
April 2, 2024

 

[Official Guidance]

Text of DOL Final Amendment to Prohibited Transaction Class Exemption 84-14: Transactions Determined by Independent Qualified Professional Asset Managers (the QPAM Exemption)

189 pages. "[T]his amendment: [1] requires a QPAM to provide a one-time notice to the Department that the QPAM is relying upon the exemption; [2] updates the list of crimes enumerated in the prior version of Section I(g) to explicitly include foreign crimes that are substantially equivalent to the listed crimes; [3] expands the circumstances that may lead to ineligibility; and [4] provides a one-year winding down (transition) period to help Plans and IRAs avoid or minimize possible negative impacts of terminating or switching QPAMs or adjusting asset management arrangements when a QPAM becomes ineligible pursuant to Section I(g), and gives QPAMs a reasonable period to seek an individual exemption, if appropriate. This amendment also: [1] provides clarifying updates to Section I(c) regarding a QPAM's authority over investment decisions; [2] adjusts the asset management and equity thresholds in the QPAM definition in Section VI(a); and [3] adds a new recordkeeping provision in Section VI(u)."  MORE >>

Employee Benefits Security Administration [EBSA], U.S. Department of Labor [DOL]

[Guidance Overview]

DOL Announces Final Amendment to 'QPAM Exemption'

"The final amendment ... responds to substantial changes in the financial services industry since the exemption's 1984 establishment. Among these changes are industry consolidation and the increasing global reach of financial services institutions in their affiliations and investment strategies, including those that manage plan and IRA assets."  MORE >>

Employee Benefits Security Administration [EBSA], U.S. Department of Labor [DOL]

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BenefitsLink® Retirement Plans Newsletter, ISSN no. 1536-9587.

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