Log in or register
Share on LinkedInShare on LinkedIn

ARTICLE · 26 AUGUST 2022

DOL Issues Proposed Amendment To QPAM Exemption

Foley Hoag LLP
Explore more from Foley Hoag LLP

The Department of Labor ("DOL") recently issued a proposed amendment to prohibited transaction class exemption 84-14 (the "QPAM Exemption"). The QPAM Exemption permits an investment...

United StatesWealth Management
Teresa Martland
Teresa Martland
Author LinkedIn connections

Key Takeaways:

The DOL is proposing an amendment to the QPAM exemption that (among other things) would:

  • expand the types of misconduct that can result in a QPAM's ineligibility to rely on the QPAM exemption;
  • significantly increase the asset management and equity thresholds for QPAMs;
  • impose new reporting and recordkeeping requirements on QPAMs; and
  • require amendments to existing QPAM investment management agreements.

The Department of Labor ("DOL") recently issued a proposed amendment to prohibited transaction class exemption 84-14 (the "QPAM Exemption"). The QPAM Exemption permits an investment fund managed by a qualified professional asset manager ("QPAM") to engage in certain otherwise ERISA prohibited transactions with a "party in interest" to a qualified benefit plan ("Plan") invested in the fund. Currently, there are no reporting or recordkeeping requirements for relying on the QPAM Exemption. The proposed amendment, which is intended

We operate a free-to-view policy, asking only that you register in order to read all of our content. Please login or register to view the rest of this article.

Register for freeORLog in

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

View source

Related Articles

Legal Intelligence Newsletters: sign up for the latest legal and regulatory news on your chosen topics

Read more about

See more popular content from

Article

Dividing A Grandfathered Trust Without Tax Cost: Lessons From PLR 202641001

Families change. Dynasty trusts set up by one generation may stop fitting the family that inherits them. Over time, grandchildren and great-grandchildren can end up wanting very different things from the same pool of assets. In PLR 202641001, released October 9, 2026, the IRS approved a trustee’s plan to split a long-standing family trust into three equal trusts. It concluded that the division would not trigger generation-skipping transfer (GST), income, or gift tax consequences.
United StatesWealth Management
Farrell Fritz
Farrell Fritz
Article

Navigating Florida’s New Trust, Probate And Series LLC Statutes

Florida has enacted significant statutory changes affecting trust administration, probate procedures, and business entity formation. These reforms introduce streamlined nonjudicial processes for trustee discharge, expand access to simplified probate administration, and establish a new framework for protected series LLCs that offers enhanced asset protection and operational flexibility for estate planners and business owners.
United StatesWealth Management
Withers LLP
Withers LLP
Article

The Great Wealth Transfer: What An $84 Trillion Shift Between Generations Means For Your Estate Plan

As the Silent Generation and Baby Boomers prepare to transfer an estimated $84-90 trillion in wealth over the next two decades, families face critical decisions about estate planning, tax strategies, and asset protection. This comprehensive analysis explores how changing tax laws, evolving family structures, and complex asset portfolios require thoughtful planning to preserve wealth across generations while avoiding unnecessary taxes, legal disputes, and family conflicts.
United StatesWealth Management
Conn Kavanaugh Rosenthal Peisch & Ford LLP
Conn Kavanaugh Rosenthal Peisch & Ford LLP
Article

Using Offshore Trusts For Private Equity Investments And Wealth Preservation

High-net-worth individuals and private equity investors increasingly explore offshore trusts as sophisticated wealth planning tools that may provide enhanced asset protection, investment management flexibility, and multigenerational wealth preservation. Understanding the strategic benefits, tax implications, and compliance requirements of these complex structures is essential for entrepreneurs, executives, and families seeking to protect significant holdings while maintaining appropriate control and meeting
United StatesWealth Management
MGO CPA LLP
MGO CPA LLP
Article

The Creator Economy Meets Estate Planning: Protecting And Transferring Digital Businesses

As the creator economy continues to expand, individuals who derive income from digital platforms face a critical estate planning question. For those who already have an estate plan, that plan may not adequately address the unique challenges of managing, valuing and transferring digital businesses, leaving these increasingly valuable assets vulnerable to confusion, lost revenue and family conflict.
United StatesWealth Management
Wiggin and Dana LLP
Wiggin and Dana LLP
Article

California Requires Disclosure Of AI-Generated People In Advertising

California has enacted a groundbreaking AI disclosure law requiring advertisers to clearly identify when synthetic performers appear in their marketing materials. The legislation, set to take effect in 2027, includes a private right of enforcement that could potentially open the door to class action litigation against brands using AI-generated performers without proper disclosure.
United StatesMedia, Telecoms, IT, Entertainment
Foley Hoag LLP
Foley Hoag LLP
Article

Virginia’s Initial Draft Of Adult-use Marijuana Regulations – What You Should Know And What Questions Remain

Virginia's Cannabis Control Authority has released its initial draft of adult-use marijuana regulations, outlining application fees, license caps, and the approval process for the state's anticipated July 2027 launch of recreational cannabis sales. While the draft provides crucial details on licensing requirements and ownership restrictions, significant questions remain about the application timeline and evaluation criteria that will determine which entities receive coveted permits.
United StatesConsumer Protection
Foley Hoag LLP
Foley Hoag LLP
Article

Rising Cyberattacks On U.S. Water Infrastructure: Federal Guidance And Next Steps For Operators

Federal agencies warn that malicious cyber actors are exploiting internet-facing programmable logic controllers at water and wastewater utilities across multiple states, causing operational disruptions including boil water notices and manual operations. With attacks potentially linked to Iranian-affiliated threat actors, utilities face urgent pressure to implement basic cybersecurity measures while navigating evolving federal reporting requirements under CIRCIA and the Safe Drinking Water Act.
United StatesTechnology
Foley Hoag LLP
Foley Hoag LLP
Article

FDA Holds Landmark Public Hearing On The Future Therapeutic Use Of Psychedelic Drugs

The FDA, in collaboration with federal partners, held a landmark public hearing on September 14, 2026, to gather input on the future therapeutic use of psychedelic drugs, drawing over 18,000 registered attendees. This hearing represents one of the earliest implementations of Executive Order 14401, which directs federal agencies to expedite research, review, and approval of psychedelic drugs for serious mental health conditions.
United StatesFood, Drugs, Healthcare, Life Sciences
Foley Hoag LLP
Foley Hoag LLP
Article

UPDATE: DEA Publishes Registration Applications For Medical Marijuana Manufacturers, Distributors, And Analytical Labs

The DEA has opened new registration portals for medical marijuana manufacturers, distributors, and analytical labs, expanding beyond the dispensary registration that became available earlier this year. These applications require extensive business information and background disclosures, with fees ranging from $296 to $3,699, and may provide significant compliance and commercial benefits for cannabis businesses operating under state medical marijuana programs.
United StatesGovernment, Public Sector
Foley Hoag LLP
Foley Hoag LLP
Article

OCC Proposes BSA/AML And Sanctions Compliance Standards For Permitted Payment Stablecoin Issuers Under The GENIUS Act

The Office of the Comptroller of the Currency has proposed new regulations that would impose Bank Secrecy Act and sanctions compliance requirements on permitted payment stablecoin issuers under its jurisdiction. This rulemaking, coordinated with FinCEN and OFAC, establishes anti-money laundering, counter-terrorism financing, and sanctions program standards for stablecoin issuers as part of the broader implementation of the GENIUS Act framework.
United StatesFinance and Banking
Foley Hoag LLP
Foley Hoag LLP