Preparing for Changes to the QPAM Exemption

Lowenstein Sandler LLP
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Megan Monson, Andrew E. Graw, Taryn E. Cannataro of Lowenstein’s Employee Benefits & Executive Compensation group discuss with partner Marie DeFalco, Co-Chair of the firm’s Investment Management group, the significance of the QPAM exemption from ERISA prohibitions on transactions with a party in interest for investment advisers. The group explains current and possible new requirements for qualifying for the QPAM exemption; registration and recordkeeping rules; the potential impact of raising the required total AUM; and how the lack See more +
Megan Monson, Andrew E. Graw, Taryn E. Cannataro of Lowenstein’s Employee Benefits & Executive Compensation group discuss with partner Marie DeFalco, Co-Chair of the firm’s Investment Management group, the significance of the QPAM exemption from ERISA prohibitions on transactions with a party in interest for investment advisers. The group explains current and possible new requirements for qualifying for the QPAM exemption; registration and recordkeeping rules; the potential impact of raising the required total AUM; and how the lack of a lack of a “grandfathering” period can prove a challenge for investment advisers.

Episode Resources:

* DOL Proposes Significant Changes to the QPAM Exemption for Managing ERISA Assets: https://bit.ly/3VCJxCS

* Plan Fiduciaries, Including Investment Advisers and Fund Managers, Take Note – U.S. Department of Labor Proposes Enhanced QPAM Requirements: https://bit.ly/3zqczeA

Speakers:

Megan Monson, Partner, Employee Benefits & Executive Compensation

Andrew E. Graw, Partner and Chair, Employee Benefits & Executive Compensation

Taryn E. Cannataro, Associate, Employee Benefits & Executive Compensation

Marie DeFalco, Partner and Co-Chair, Investment Management Group

Subscribe to Lowenstein Sandler’s Employee Benefits & Executive Compensation Podcast: Just Compensation via Apple Podcasts/iTunes, Google Podcasts, SoundCloud, Spotify, and YouTube. See less -

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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