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ARTICLE · 22 AUGUST 2024

QPAM Exemption Initial Notification Deadline Nearing

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On April 2, 2024, the US Department of Labor (DOL) issued an amendment establishing new rules (New QPAM Rules) for what is commonly referred to as the "QPAM Exemption." The QPAM Exemption is the main...

United StatesEmployment and HR
Mitchel C. Pahl
Mitchel C. Pahl
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On April 2, 2024, the US Department of Labor (DOL) issued an amendment establishing new rules (New QPAM Rules) for what is commonly referred to as the "QPAM Exemption." The QPAM Exemption is the main exemption relied upon by investment advisers and managers who provide services to employee benefit plans and individual retirement accounts that are subject to certain "prohibited transaction" rules under ERISA and/or the Internal Revenue Code.

Among other changes, the New QPAM Rules require investment advisers and asset managers who rely on the QPAM Exemption (QPAM) to send a notice to the DOL via email. The notice must be provided within 90 calendar days of first reliance on the QPAM Exemption and should identify the legal name (and d/b/a name) of each business entity relying on the QPAM Exemption.

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