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DOL Proposes Stricter Requirements for All Managers Relying on the Qualified Professional Asset Manager (QPAM) Exemption

On July 27, 2022, the U.S. Department of Labor (DOL) published in the Federal Register a proposed amendment to the qualified professional asset manager (QPAM) class prohibited transaction exemption 84-14 (PTE 84-14 or QPAM Exemption), which would make it more difficult to rely on the exemption in certain circumstances, including when the QPAM, its affiliates or any 5% or more owners have been convicted of certain crimes.

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The SEC Strikes Again: Undisclosed Executive Perks & Related Person Transactions


Time to Read: 1 minutes Practices: Executive Compensation & Employee Benefits, Securities & Public Companies

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Two recent SEC enforcement actions involving executive perks and related person transactions are a reminder that disclosure deficiencies in these areas can attract SEC scrutiny. The extent to which this represents a new trend or merely the carryover of investigations started under the prior leadership remains to be seen, but the recent activities warrant renewed attention to these matters.

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