Update: Following the U.S. District Court for the Eastern District of Texas’s stay of the Final Rules and related amendments to PTE 84-24 in Fed’n of Americans for Consumer Choice (discussed below), the very next day the U.S. District Court for the Northern District of Texas issued a broader stay in American Council of Life
A Pop Culture Guide to the Final Amendments to the QPAM Exemption Taking Effect on June 17, 2024
The DOL recently finalized amendments to the QPAM exemption that will considerably alter the exemption’s conditions effective as of June 17, 2024 (for a detailed summary of the changes, please see our post here). There are a number of immediate action items for investment managers and ERISA plan fiduciaries under the revised exemption, so
Goodbye “Five-Part Test”—DOL Finalizes New Investment Advice Fiduciary Rules
On April 23, 2024, the Department of Labor (“DOL”) issued final rules which expand what it means to provide fiduciary “investment advice” under the Employee Retirement Income Security Act of 1974, as amended (“ERISA”) and Section 4975 of the Internal Revenue Code of 1986, as amended (the “Code”). Though the final rules broaden the definition
DOL Unveils Final Amendment to QPAM Exemption
On April 3, 2024, the U.S. Department of Labor (the “DOL”) published in the federal register a final amendment to Prohibited Transaction Class Exemption 84-14 (the “QPAM Exemption”) that makes considerable changes to the exemption’s conditions (the “Final Amendment”). Although the Final Amendment trims back some of the more onerous requirements floated in the proposed