On April 3, 2024, the Department of Labor (DOL) published in the Federal Register long-awaited final amendments to Prohibited Transaction Class Exemption 84-14 (the Amendment), also known as the Qualified Professional Asset Management (QPAM) exemption (the Exemption). The Amendment (i) imposes new notice and reporting requirements and increased financial thresholds, as conditions to relying on the Exemption; (ii) reiterates the DOL’s view that QPAMs must be independent and have sole discretionary authority with respect to transactions covered by the Exemption; and (iii) modifies Section I(g) of the Exemption.

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Photo of Nathan M. Iacovino Nathan M. Iacovino

Nathan M. Iacovino focuses his practice on the investment servicing and investment management industries, advising asset-servicing entities, including custodians, transfer agents, and administrators, in connection with various regulatory and transactional matters. He has supported and developed strategies related to the structuring, negotiation, and

Nathan M. Iacovino focuses his practice on the investment servicing and investment management industries, advising asset-servicing entities, including custodians, transfer agents, and administrators, in connection with various regulatory and transactional matters. He has supported and developed strategies related to the structuring, negotiation, and implementation of domestic and global custody, fund administration, managed account platforms, collateral management, and related servicing arrangements by and among his custodial, investment servicing and managed account platform provider clients and their respective fund, investor, pension plan, and adviser client base.

Nathan also represents mutual fund complexes, asset managers, investment advisers, institutional investors and financial institutions in developing and maintaining financial products while navigating the regulatory landscape.

Nathan’s clients include a wide range of private funds, registered investment companies, transfer agents, banks, financial institutions, institutional investors and investment advisors.

Hope Adams

Hope Adams focuses her practice on the asset management and financial services industry, advising banking institutions and investment managers on a wide range of regulatory, transactional, asset servicing, product structuring and private fund matters.

With over three decades of experience, including 13 years…

Hope Adams focuses her practice on the asset management and financial services industry, advising banking institutions and investment managers on a wide range of regulatory, transactional, asset servicing, product structuring and private fund matters.

With over three decades of experience, including 13 years as senior legal counsel supporting the asset management operations and private fund investment activities of a large U.S. national bank, Hope has developed a wide-ranging understanding of the intersection of regulatory and operational risks and the business objectives of the institution. Based on her in-house experience, Hope strongly believes that an effective lawyer will first understand the client’s objectives and limitations and then provide practical and risk appropriate alternatives, whether related to the implementation of new regulations, managing regulatory audits, drafting contracts or internal policies and procedures or advising on the development and launch of new products, services or private funds.