Preparing for Changes to the QPAM Exemption

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
• Plan Fiduciaries, Including Investment Advisers and Fund Managers, Take Note – U.S. Department of Labor Proposes Enhanced QPAM Requirements

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