Dechert Submits Comment on DOL’s Proposed QPAM Amendments

The Department of Labor (the “DOL”) made a proposal (the “Proposal”) on July 27, 2022 to make a number of changes to Prohibited Transaction Class Exemption 84-14 (the “QPAM Exemption”). The QPAM Exemption is a key exemption that generally provides relief from the so-called “per se” prohibitions of the Employee Retirement Income Security Act of 1974 (“ERISA”) for transactions between ERISA-covered employee benefit plans (“Plans”) and “parties in interest” (or “disqualified persons” under the tax code), where the Plan is managed by a qualified professional asset manager and the other conditions of the QPAM Exemption are met. Dechert submitted a comment letter to the DOL regarding the proposal, which is included for your information with the NewsFlash that is attached to this email.