On July 27, 2022, the US Department of Labor (DOL) released
Proposed Amendment (Proposal) to PTCE 84-14 (QPAM Exemption), which
is commonly utilized by financial institutions to conduct routine
transactions involving private sector retirement plans and
individual retirement accounts (Plans) that would otherwise be
treated as a prohibited transaction under ERISA or the Internal
Revenue Code. The proposed changes are significant and, if adopted,
would impact banks, registered investment advisers, hedge funds,
and other financial services firms and counterparties that provide
products and services to, or transact with, Plans or plan asset
vehicles.
Key changes in the Proposal are summarized below.