1 Analyses of this federal-register by attorneys

  1. The Department of Labor Finalizes Changes to the QPAM Exemption - A Favored Management Tool Gets Less User-Friendly

    GoodwinJohn ClearyApril 9, 2024

    ng, and compliance) to address the changes in the exemption conditions, including systems to monitor for disqualifying events across all covered affiliates;Consider the potential for, and impact of, disqualification on existing businesses and strategies and whether to develop a contingency plan (e.g., whether alternative exemptions will work and, if not, whether and to what extent the transition period requirements will impact current relationship structures and agreements, including termination and liquidity provisions). If a contingency plan is already in place, consider modifications in light of the new requirements;Consider any increase in the risk of disqualification prior to a merger, acquisition or other corporate action; andFor managers with governmental plan clients contractually requiring compliance with the QPAM Exemption, consider the impact of the changes on those client relationships, including whether the changes even apply and, if so, whether to negotiate alternatives. 89 Fed. Reg. 23090 (April 3, 2024), available at https://www.govinfo.gov/content/pkg/FR-2024-04-03/pdf/2024-06059.pdf The Employee Retirement Income Security Act of 1974, as amended.[View source.]