Reminder of the June 30, 2013 deadline for QPAM Exemption Audit

If you (or an affiliate) maintained and managed a 401(k) or a defined benefit plan in 2012 that invested in private investment funds which were subject to ERISA, an independent auditor must conduct an exemption audit by June 30, 2013 for the QPAM Exemption to apply to the plan.


The exemption audit must consist of the following:

  • A review of the written policies and procedures adopted by the QPAM;
  • A test of a representative sample of the account’s transactions during the audit period;
  • A determination as to whether the QPAM has satisfied the definition of a “QPAM” under the QPAM Exemption;
  • Issuance of a written report describing the steps performed by the auditor and the auditor’s findings;
  • The audit report must disclose whether the QPAM is in compliance with (i) such written policies and procedures adopted by the QPAM and (ii) the objective requirements of the exemption; and must render an overall opinion regarding the level of compliance of the program;
  • The exemption audit must be completed within six months following the end of the year to which it relates.

For more information review the attached link Department of Labor Release or call Orical LLP at (212) 705-4285.

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