DOL Unveils Final Amendment To QPAM Exemption

On April 3, 2024, the U.S. Department of Labor (the "DOL") published in the federal register a final amendment to Prohibited Transaction Class Exemption 84-14 (the "QPAM Exemption") that makes considerable changes to the exemption's conditions (the "Final Amendment"). Although the Final Amendment trims back some of the more onerous requirements floated in the proposed amendment issued by the DOL in July 2022 (which we blogged about here) (the "Proposal"), the Final Amendment includes significant changes that will impact the QPAM Exemption including:

• Increasing the equity/net worth and assets under management thresholds to qualify as a "qualified professional asset manager" ("QPAM");