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Did You Send Your QPAM-A-Gram Yet? Show the DOL You Care Enough to Send the Very Best

On April 3, 2024, the Department of Labor (the “DOL”) issued its final amendment (“Amendment”) to Prohibited Transaction Class Exemption 84-14, commonly referred to as the “QPAM Exemption”....more

Texas Court Issues DOL Fiduciary STAYcation

On July 25, 2024, the U.S. Federal Court for the Eastern District of Texas issued a stay (the “Stay”) on the effective date of the Department of Labor’s (“DOL”) 2024 investment advice fiduciary rule (the “2024 Fiduciary...more

Going Beyond One’s “Conviction(s)”? DOL Proposes Significant Changes to QPAM Exemption

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...more

How Secure Is a Securitization’s "Debt" Classification for ERISA Purposes? Pending Sub-Prime Lawsuit Asks Court to Look Through...

The case is particularly noteworthy in that it marks the first time of which we are aware that a judicial decision (even an interlocutory one) has expressly raised the issue of whether the sponsors’ debt characterization of...more

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