Regulatory Alerts2024-08-13 | FIL-55-2024Qualified Professional Asset Manager (QPAM) Exemption Amendment
The U.S. Department of Labor amended its Prohibited Transaction Class Exemption 84-14 to require FDIC-supervised institutions relying on the Qualified Professional Asset Manager (QPAM) exemption to submit a one-time notice of intent. The revised framework imposes phased asset management and equity thresholds, expands the list of disqualifying misconduct and entities, and mandates a six-year recordkeeping period. Banks must file their initial notification by September 15, 2024, within a ninety-day window that includes an additional ninety-day cure period for inadvertent reporting failures.
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