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DOL’s proposed QPAM amendments may amount to an effective revocation of the exemption

In the guise of clarifications relating to criminal convictions and misconduct, the Department of Labor (DOL) has proposed major amendments to Prohibited Transaction Exemption (PTE) 84-14, also known as the QPAM exemption...more

Unlocking the process: Guide to ERISA individual prohibited transaction exemptions

Since 1996, the US Department of Labor granted more than 1,200 individual exemptions from the ERISA prohibited transaction rules. One of the distinctive features of ERISA is its prohibition, in ERISA section 406 as a...more

DOL issues RFI on a possible ERISA class exemption for PEP/MEP plans

On June 18, 2020, the US Department of Labor (DOL) published a request for information (RFI), in advance of its potential proposal of a class exemption (PTE) providing relief for ERISA prohibited transactions arising in the...more

2019 in review - ERISA guidance

In 2019, the Department of Labor (DOL) continued its trend of providing limited advance guidance under the Employee Retirement Income Security Act of 1974, as amended (ERISA). By volume, the amount of 2019 guidance...more

Legal Alert: 2016 Year in Review

In 2016, the Department of Labor (DOL) continued a curtailed program of interpretive guidance under the Employment Retirement Income Security Act of 1974, as amended (ERISA). As has been the case for several years, the...more

2014 in Review: ERISA Individual Prohibited Transaction Exemptions and Advisory Opinions

In 2014, the Department of Labor (DOL) maintained a diminished program of advance guidance under the Employment Retirement Income Security Act of 1974, as amended (ERISA), in response to requests from the regulated community....more

Legal Alert: DOL Proposes to Substitute Creditworthiness Determinations for Credit Ratings in ERISA Prohibited Transaction Class...

On June 21, 2013, the Department of Labor (DOL) published proposed amendments to certain class exemptions required by Section 939 A of the Dodd-Frank Wall Street Reform and Consumer Protection Act, which directs federal...more

2012 in Review: ERISA Individual Prohibited Transaction Exemptions

In 2012, the Department of Labor (DOL) continued a fairly active program of issuing individual exemptions from the prohibited transaction rules of ERISA. These rules generally prohibit, among other things: - Sale and...more

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