DOL Recent Amendment to the QPAM Exemption: Key Provisions and Challenges for Asset Managers and ERISA Plan Sponsors

On 3 Apr. 2024, the DOL finalized a substantial amendment to the qualified professional asset manager (QPAM) prohibited transaction class exemption, PTE 84-14, which amendment is effective 17 June 2024. The QPAM amendment includes strict requirements and compliance obligations for investment managers seeking to qualify for the exemption. The amendment also adds new categories of conduct that will disqualify managers from relying on the exemption.

The panel will discuss key provisions impacting asset managers and plan sponsors, reporting and record keeping requirements, eligibility criteria, conduct that would result in ineligibility, the process for requesting an individual prohibited transaction exemption from the DOL in the event of ineligibility for relief under the QPAM exemption, and other key issues stemming from the final amendment to the QPAM exemption.

The panel will discuss these and other key issues:

• What are the key provisions of the DOL amendment to the QPAM exemption?
• How does the amendment to the exemption impact investment managers and plan sponsors?
• What activities will be considered disqualifying under the exemption?
• What are the conditions for relief under the QPAM exemption and current limitations on the scope of relief?
• What are the next steps for plan sponsors and investment fiduciaries?

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