News & Analysis as of

Asset Management Exemptions

Foley & Lardner LLP

Reminder: Qualified Professional Asset Managers (QPAM) Notice Deadline is September 15, 2024

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Earlier this year, the Department of Labor (DOL) updated the prohibited transaction exemption for Qualified Professional Asset Managers, often referred to as the “QPAM exemption.” Included in the update is a new requirement...more

Foley Hoag LLP

QPAM Amendment – Action Required by Investment Managers

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The U.S. Department of Labor (“DOL”) has amended the qualified professional asset manager (“QPAM”) class prohibited transaction exemption 84-14 (“QPAM Exemption”), effective as of June 17, 2024 (“QPAM Amendment”)....more

Stark & Stark

DOL Publishes Final QPAM Exemption Amendment

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On April 3, 2024, the U.S. Department of Labor (DOL) published a final amendment to Prohibited Transaction Class Exemption 84-14. The amendment will become effective June 17, 2024....more

K&L Gates LLP

The US Corporate Transparency Act: Practical Considerations for Private Fund Sponsors as the Effective Date Approaches

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Earlier this year, the US Congress passed the Corporate Transparency Act (CTA). The CTA will require thousands of privately held US and non-US entities to report beneficial ownership to the US Treasury Department’s Financial...more

Foley Hoag LLP

DOL Issues Proposed Amendment to QPAM Exemption

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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...more

Morgan Lewis

US Department of Labor Proposes Extensive Changes to QPAM Exemption

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The US Department of Labor (DOL) published in the July 27, 2022, Federal Register a number of proposed changes to Prohibited Transaction Class Exemption (PTE) 84-14, the so-called “QPAM Exemption.” Investment managers of US...more

Seward & Kissel LLP

DOL Proposes an Amendment to the QPAM Exemption

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On July 27, 2022 the U.S. Department of Labor (DOL) proposed significant modifications to Prohibited Transaction Class Exemption 84-14 (the QPAM Exemption). The DOL will accept written comments and requests for public...more

Goodwin

SEC Adopts Rule Providing New Regulatory Framework For Fund-Of-Funds

Goodwin on

In the News. The Securities and Exchange Commission (SEC) announced that it adopted Rule 12d1-4 under the Investment Company Act of 1940 (the 1940 Act), providing a new regulatory framework for fund-of-funds and final...more

K&L Gates LLP

Finders Keepers? SEC Proposes Exemption from Broker-Dealer Registration for Finders in Private Placements, but Questions Remain

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OVERVIEW - On October 7, 2020, the U.S. Securities and Exchange Commission (SEC) proposed a conditional exemption, operating as a nonexclusive safe harbor from the broker registration requirements of Section 15(a) of the...more

Akin Gump Strauss Hauer & Feld LLP

CFTC and NFA Year End Regulatory Updates

• Effective January 1, 2020, clarifying amendments to rules regarding communications with the public and use of promotional material will go into effect. • Effective February 1, 2020, CTA will be subject to new limitations...more

Dechert LLP

Investment Funds Update Europe: Legal and regulatory updates for the funds industry from the key asset management centres and...

Dechert LLP on

Entry into force of MiFID II - The Directive 2014/65/EU on Markets in Financial Instruments (MiFID II) entered into force in France on 3 January 2018. Within the framework, the French legal framework has been updated over...more

Morgan Lewis

GPs Operating in Japan: Follow-Up Information Disclosures for Article 63 Filers Is Required

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GPs that operate limited partnerships based on the exemption under Article 63 of the FIEA and have recently completed a renewal filing around the end of the grace period (August 31, 2016) are required to prepare Form 20-2...more

Morgan Lewis

The Effect of Article 63 Amendments on Existing Article 63 Exemption Operators

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Existing Article 63 Exemption Operators will be subject to new obligations and duties starting March 1, 2016. Beginning March 1, 2016, the amendments to the exemption concerning the Special Business Activities for...more

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