See Credit Details Below
Overview
On April 3rd, the Department of Labor finalized its much-anticipated amendments (the “Final Amendments”) to Prohibited Transaction Exemption 84-14 for Transactions Determined by Independent Qualified Professional Asset Managers (the “QPAM Exemption”). The QPAM Exemption provides “prohibited transaction” relief for transactions directed by managers who are “qualified professional asset managers” or “QPAMs.” The Final Amendments become effective on June 17, 2024. Before the effective date, managers will need to decide whether they can continue to rely on the QPAM Exemption and the changes necessary or desirable to their existing compliance measures. In addition, plans may need to consider whether to agree to proposed contract amendments from existing managers who will no longer rely on the QPAM Exemption.
Specific issues to be addressed include:
- Background of the QPAM Exemption (10 minutes)
- Description of Final Amendments (30 minutes)
- Discussion of potential impact of the Final Amendments (20 minutes)
Who Should Attend: Outside attorneys, in-house counsel, plan counsel, compliance, finance, and other professionals interested in learning more about the Final Amendments.
Program Level: Update
Prerequisites: None
Advanced Preparation: None
Faculty:
Chris Cosby
U.S. Department of Labor
Elizabeth L. Dyer
Cleary Gottlieb Steen and Hamilton LLP
Linda J. Haynes
Seyfarth Shaw LLP