The Employer’s Wage and Hour Advisor

The U.S. Department of Labor (“DOL”) recently published amendments to narrow the Class Prohibited Transaction Exemption (PTE), also known as the qualified professional asset manager (“QPAM”) Exemption. The exemption allows QPAMs to manage multiple investments, notwithstanding general prohibitions under the Employee Retirement Income Security Act (“ERISA”). Under the amendments, QPAMs are ineligible for the exemption if they committed certain criminal conduct. The DOL also requires QPAMs to be more transparent by changing reporting and administrative duties. The effective date of this new amendment is July 17, 2024.