EMAIL DETAILS
SUBJECT:
QPAM
FROM:
A
abusch@rosemontseneca.com
DATE:
2010-07-30 19:30:23
MSG_ID:
<933883569-1280518169-cardhu_decombobulator_blackberry.rim.net-447562064-@bda647.bisx.prod.on.blackberry>
RECIPIENTS:
TO:
M
Marc LoPresti
<mxl@tlcorplaw.com>
CC:
D
Devon Archer
<darcher@rosemontseneca.com>
E
Eric Schwerin
<eschwerin@rosemontseneca.com>
H
Hunter Biden
<hbiden@rosemontseneca.com>
CONTENT:
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PROCESSED
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
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