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FINANCIAL INSTITUTION LETTER | AUGUST 13, 2024 |
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Qualified Professional Asset Manager (QPAM) Exemption Amendment
SUMMARY:
This issuance is intended to notify FDIC-supervised institutions of an amendment of the U.S. Department of Labor’s (DOL) Prohibited Transaction Class Exemption rule (PTE 84-14) for Qualified Professional Asset Manager (QPAM) exemptions. The QPAM Exemption (hereafter, PTE 84-14) provides broad relief for employee benefit plan and individual retirement account transactions that would otherwise be prohibited by Title I of the Employee Retirement Income Security Act of 1974, as amended (ERISA) and Title II of ERISA, as codified in the Internal Revenue Code of 1986, as amended, as long as the transactions involve a QPAM. Under the prior rule, QPAMs did not need to notify the DOL that they were relying on the Exemption. However, under the newly amended rule, a one-time notice is now required in order to continue to rely on the Exemption, provided certain conditions are met.
STATEMENT OF APPLICABILITY:
The contents of, and material referenced in, this FIL apply to all FDIC-supervised financial institutions.
DISTRIBUTION:
FDIC-Supervised Financial Institutions
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