Not Quite QPAMdemonium: DOL Issues Final Changes To The QPAM Exemption

On April 3, 2024, the Department of Labor (the "DOL") issued its final amendment ("Final Amendment") to Prohibited Transaction Class Exemption 84-14, commonly referred to as the "QPAM Exemption".

Generally, the QPAM Exemption offers relief from the prohibitions of Section 406(a) of the Employee Retirement Income Security Act of 1974, as amended ("ERISA") and the corresponding provisions of Section 4975 of the Internal Revenue Code of 1986, as amended (the "Code") ("Prohibited Transactions") for transactions involving retirement plans and other entities that are subject to the prohibited transaction provisions of ERISA or the Code (collectively "Plans") with "parties in interest" (or "disqualified persons" within the meaning of the Code), where the Plan is managed by an entity that meets the definition of a "qualified professional asset manager" (a "QPAM") and the other requirements of the QPAM Exemption are met.