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ARTICLE · 15 FEBRUARY 2024

DOL Finalizes More Stringent Procedures For Requesting Prohibited Transaction Exemptions

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The Department of Labor's ("DOL") prohibited transaction exemption procedures provide an opportunity for plan sponsors, service providers, industry groups, or others to apply for permission...

United StatesEmployment and HR
Jim Cole
Jim Cole
Allison Itami
Allison Itami
Scott Mayland
Scott Mayland
George Sepsakos
George Sepsakos
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The Department of Labor's ("DOL") prohibited transaction exemption procedures provide an opportunity for plan sponsors, service providers, industry groups, or others to apply for permission to engage in a variety of transactions involving employee benefit plans covered by the Employee Retirement Income Security Act of 1974, as amended ("ERISA") and IRAs. On January 24, 2024, the DOL published final amendments to its regulations governing these procedures (the "Final Amendments"). Among other things, the Final Amendments would increase the information applicants for an exemption would need to provide; impose more requirements on independent fiduciaries, appraisers, accountants and auditors representing plans or IRAs in connection with exemption transactions; and provide more discretion for the DOL to deny an application for an exemption. These changes will be effective for prohibited transaction exemption applications filed with the DOL on and after April 8, 2024.

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