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ARTICLE · 16 APRIL 2024

Amendment To QPAM Exemption

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On April 2, 2024, the Department of Labor ("DOL" or "Department") released an amendment (the "Amendment") to Prohibited Transaction Exemption 84-14 (the "QPAM Exemption" or "Exemption").

United StatesEmployment and HR
Jennifer Eller
Jennifer Eller
David Kaleda
David Kaleda
Michael Kreps
Michael Kreps
Eboni Onuoha
Eboni Onuoha
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On April 2, 2024, the Department of Labor ("DOL" or "Department") released an amendment (the "Amendment") to Prohibited Transaction Exemption 84-14 (the "QPAM Exemption" or "Exemption"). The changes were proposed by DOL in July 2022 (the "Proposal") and primarily aimed at expanding the QPAM Exemption's provisions disqualifying asset managers from relying on the Exemption if they or their affiliates engage in certain criminal activity or in other activity that, in the Department's view, should render an asset manager ineligible to be a "qualified professional asset manager" ("QPAM"). While the Amendment retains many of the changes in the Proposal, there are also several improvements to the Proposal, which should make complying with the Amendment less onerous on asset managers. The Amendment was published in the Federal Register on April 3, 2024, and will be effective on June 17, 2024.

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