Maybe Not Such a Bad Actor – Department of Labor Clarifies

November 11, 2013

The U.S. Department of Labor (the “Department”) on November 1, 2013 issued Advisory Opinion 2013-05A (the “Opinion”) concerning the application of certain anti-criminal provisions under the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). In particular, as discussed below, the Opinion generally provides clarification regarding what may be considered a “conviction” for purposes of Prohibited Transaction Class Exemption 84-14 (the “QPAM Exemption”).

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