DOL Reopens Comment Period on Proposed Amendments to "QPAM" Class Exemption

The DOL reopened the comment period on the Employee Benefits Security Administration’s proposed amendments to Prohibited Transaction Class Exemption 84-14 (the Qualified Professional Asset Manager or "QPAM" Exemption).

The QPAM Exemption allows regulated entities, such as registered investment advisers, banks, savings and loan associations and insurance companies that meet the criteria set forth in the exemption to engage in certain activities related to ERISA plan assets that would otherwise be prohibited transactions. If adopted, the proposed amendments would substantially expand the conditions for compliance.

The proposed amendments were first published on July 27, 2022, with a comment deadline of September 26, 2022. The comment deadline was first extended to October 11, 2022. The DOL subsequently held a virtual public hearing on the proposal on November 17, 2022, and reopened the comment period from the hearing date until January 6, 2023.

The new comment deadline for the proposal is April 6, 2023.

For more information on the proposal, read Fried Frank's analysis, "Imagining a World without QPAM."