DOL Makes Significant Changes To QPAM Exemption

On April 3, 2024, the Department of Labor (DOL) published in the Federal Register long-awaited final amendments to Prohibited Transaction Class Exemption 84-14 (the Amendment), also known as the Qualified Professional Asset Management (QPAM)¹ exemption (the Exemption).² The Amendment (i) imposes new notice and reporting requirements and increased financial thresholds, as conditions to relying on the Exemption; (ii) reiterates the DOL's view that QPAMs must be independent and have sole discretionary authority with respect to transactions covered by the Exemption; and (iii) modifies Section I(g) of the Exemption, a provision under which a QPAM may become ineligible to rely upon the Exemption for a period of 10 years if the QPAM, various affiliates, or 5% or more owners of the QPAM are convicted of certain crimes and engage in certain prohibited misconduct. The Amendment is effective June 17, 2024 (Effective Date).