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Yes, thanks for catching the mistake. RIA NOT IRA.
------Original Message------
From: Eric Schwerin
To: Arlene Busch
Cc: Marc LoPresti
Cc: Hunter Biden
Cc: Devon Archer
Subject: Re: QPAM
Sent: Jul 30, 2010 4:50 PM

I assume by "IRA" you mean, "RIA - Registered Investment Advisor"?


Eric D. Schwerin
Rosemont Seneca Partners, LLC
1010 Wisconsin Ave., NW
Suite 705
Washington, DC 20007
(202) 333-1880
eschwerin@rosemontseneca.com
P Consider the environment before printing this email.

On Jul 30, 2010, at 3:30 PM, Arlene Busch wrote:

Marc,
I have written some questions below so we have all of the facts surrounding the QPAM issue. Everyone above, please feel free to add any questions I have missed.

IRA
Requirements to apply to become an IRA
Compliance
Reporting
Estimated cost for outsourcing compliance functions
Exemption from registration criteria

QPAM
Can we use affiliate assets to satisfy AUM requirements?
Reporting
Transparency (can we use underlying HF reports or do we need to create our own) monthly/quarterly: annually
All responsibilities once we have become a QPAM
The difference (if any) between Taft Hartly assets and ERISA assets
Requirement for taking ERISA assets
Definition of ERISA and what types of organizations qualify as ERISA
Criteria to be exempted from QPAM
Advisors liability: only entity, or can it spill over to personal liability? What types of circumstances would creat a lawsuit? Is liability capped at $1ML?
Can QPAM assets be co-mingled with non-QPAM assets in an offishore fund?

The above is all I can think of at the moment.

Thanks,
Arlene Busch
202-333-1880
Abusch@rosemontseneca.com


Arlene Busch
202-333-1880
Abusch@rosemontseneca.com
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