The Department of Labor (the “DOL”) on July 27, 2022, on its own initiative, proposed changes to Prohibited Transaction Class Exemption (“PTCE”) 84-14, commonly referred to as the “QPAM Exemption” (the “Proposal”). In general terms, the QPAM Exemption offers relief from the “per se” prohibitions of Section 406(a) of the Employee Retirement Income Security Act of 1974, as amended (“ERISA”) and the corresponding provisions of Section 4975 of the Internal Revenue Code of 1986, as amended (the “Code”) for transactions involving retirement plans and other entities that are subject to the prohibited transaction provisions of ERISA or the Code (collectively “Plans”) with “parties in interest” (or “disqualified persons” within the meaning of the Code1 ), where the Plan is managed by a qualified professional asset manager (a “QPAM”) and the other conditions of the QPAM Exemption are met. The Final Rule imposes a variety of new disclosure obligations on funds. The table below provides an overview of these new obligations and identifies some of the important aspects of the new disclosure requirements.