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ARTICLE · 23 APRIL 2024

QPAM Amendment Finalized: Prompt Action Required For Continued Reliance

Jones Day
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On April 3, 2024, the Department of Labor (the "DOL") published its final amendment (the "Amendment") to Prohibited Transaction Class Exemption 84-14 (the "QPAM Exemption")...

United StatesFinance and Banking
Michael Earley
Michael Earley
Rubina Ali
Rubina Ali
Laura E. Bader
Laura E. Bader
Michael Butowsky
Michael Butowsky
Thomas M. Devaney
Thomas M. Devaney
Kevin Noble
Kevin Noble
Peter Petraro
Peter Petraro
Corey L. Zarse
Corey L. Zarse
Jack Leitner
Jack Leitner
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On April 3, 2024, the Department of Labor (the "DOL") published its final amendment (the "Amendment") to Prohibited Transaction Class Exemption 84-14 (the "QPAM Exemption"), which permits certain otherwise-prohibited transactions negotiated by a qualified professional asset manager ("QPAM") for "plan asset" clients (including certain pooled funds).

The Amendment, effective on June 17, 2024, requires affirmative action by QPAMs for continued reliance.

Key elements of the Amendment include:

  • Required Notice. Every QPAM must send a one-time email notice to the DOL of reliance on the exemption (with updates for name changes). The DOL intends to maintain a list of QPAMs on its website.

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