Seyfarth Events

QPAM Compliance Audits: How Asset Managers Can Minimize Regulatory Risks and the Cost of Breach


Cost: There is no cost to attend this program, however, registration is required.


The U.S. Department of Labor estimates that there are roughly 4,400 financial organizations relying upon the DOL’s Qualified Professional Asset Manager (“QPAM”) class exemption when managing the assets of their own employee benefit plans. Maintaining QPAM status is important for these asset managers as this class exemption facilitates their ability to make investment decisions with respect to their plans without the need to monitor compliance with the prohibited transaction rules of Section 406(a) of ERISA.  Following an amendment to the QPAM class exemption by the DOL that went into effect in 2012, to secure their QPAM status when they manage the assets of plans they sponsor, financial firms must satisfy an additional hurdle to be able to meet the QPAM exemption requirements - an annual compliance audit conducted by an independent party.

With an impending June 30, 2013 deadline to complete their QPAM audits, financial firms managing assets of their sponsored ERISA plans are confronting the intricacies of this audit process. The goal of this informative and timely webinar is to help asset managers understand what is required to maintain QPAM status with respect to transactions they direct for their own plans.  Join an inter-disciplinary panel of legal, auditing and economic experts to learn about these QPAM audit requirements and how to conduct a QPAM audit.  Topics that will be covered include:

  • The QPAM exemption, why and when an audit is required;
  • QPAM audit requirements;
  • How trading activity is tested;
  • What policies and procedures must be reviewed;
  • Logistics of data gathering and examination of this data;
  • Type of report that an organization is likely to receive; and
  • Correcting any deficiencies uncovered by the audit team.

This program also will describe the consequences of non-compliance as well as the governance and risk management benefits associated with a QPAM audit.


Howard Pianko 
Seyfarth Shaw, LLP 

Mary Alcock
Cleary Gottlieb Steen & Hamilton LLP

Virginia Bartlett
Bartlett O'Neill Consulting, Inc.

Linda Haynes
Seyfarth Shaw, LLP

Susan Mangiero
Managing Director, Fiduciary Leadership, LLC

If you have any questions, please contact

*CLE: Seyfarth has applied for CLE credit in IL, NY, and CA. If you would like us to pursue CLE credit in any additional states, please contact Please note that in order to receive full credit for attending this webinar, the registrant must be present for the entire session.