Fiduciaries of plans governed by the Employee Retirement Income Security Act (“ERISA”), who hire advisers to manage plan assets on a discretionary basis, rely on these advisers to avoid engaging in transactions that are prohibited under ERISA Section 406(a). Advisers should, therefore, look to complying with applicable prohibited transaction exemptions (“PTEs”). One particularly helpful exemption is the qualified professional asset manager, or QPAM, exemption. Advisers should understand the nuances of the QPAM exemption and, first and foremost, confirm they are indeed one of these managers as the exemption defines.
To read the PLANADVISER article, “Are You a QPAM?”, where Groom principal David Kaleda discusses the nuances of a QPAM’s role and responsibilities, click here.