Christian E. Pilhofer

Jul 31, 2024 | lexology.com | Beth J. Dickstein |Christian E. Pilhofer |Paige Garcia

As previously discussed in this client Update, on April 23, 2024, the U.S. Department of Labor (DOL) released a final rule, titled the Retirement Security Rule (the Final Rule), that, among other things, amended the definition of an “investment advice fiduciary” under the Employee Retirement Income Security Act of 1974, as amended (ERISA), with respect to “retirement investors,” as defined in the Final Rule.

Jul 11, 2024 | lexology.com | Beth J. Dickstein |Christian E. Pilhofer |Paige Garcia

As previously discussed in our prior client Update regarding this topic (see also our prior client Update regarding the qualified professional asset manager (QPAM) notice requirement), on April 3, 2024, the U.S. Department of Labor (DOL) published a final amendment (the Amendment) to Prohibited Transaction Class Exemption 84-14 (the Exemption), which became effective June 17, 2024. Among other things, the Amendment instituted a new recordkeeping requirement.

Jun 17, 2024 | lexology.com | Beth J. Dickstein |Christian E. Pilhofer |Paige Garcia

As discussed in our prior client Update on this topic, on April 3, 2024, the U.S. Department of Labor (DOL) published a final amendment (the Amendment) to Prohibited Transaction Class Exemption 84-14 (the Exemption), which became effective June 17, 2024. Among other requirements, the Amendment requires a qualified professional asset manager (QPAM) to submit a one-time email notice to the DOL setting forth the legal and operating name(s) of the QPAM.

Apr 30, 2024 | lexology.com | Beth J. Dickstein |Christian E. Pilhofer |Paige Garcia

On April 23, 2024, the U.S. Department of Labor (DOL) released a final rule, titled the “Retirement Security Rule” (the Final Rule), updating the definition of an “investment advice fiduciary” under the Employee Retirement Income Security Act of 1974, as amended (ERISA).