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QPAM Primer

QPAM Exemption Requirements

In order for a lease of any commercial or residential property by a pension plan to a contributing employer to the plan, or an affiliate of such employer to qualify for exemptive relief, a separate set of requirements is applied under the QPAM exemption. These requirements are:

  • No commission may be paid to the investment manager/QPAM, the employer or any of their affiliates in connection with the lease;
  • The space leased must be suitable (or adaptable without excessive cost) for use by different tenants;
  • The amount of space covered by the lease cannot exceed 15% of the rentable space in the building in which space is leased; and

  • Neither the lease nor other employer real estate can exceed 10% of the aggregate fair market value of the assets of the plan managed by the investment manager/QPAM.

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