Prior exemptions may not reflect current policies or procedures. The Department, for example, may require terms and conditions that were not required in prior exemptions. Persons considering filing for an exemption or EXPRO authorization may find it very helpful to discuss the facts or issues in their cases with the Department before preparing the filing. The Department welcomes all inquiries and is available to answer any questions you may have. Call us at 202-693-8540.
PTE 2021-01; D-12018
DWS Investment Management Americas, Inc. (DIMA) and Certain Current and Future Asset Management Affiliates of Deutsche Bank AG (Each a DB QPAM)
Permits certain qualified professional asset managers within the corporate family of Deutsche Bank AG, including DIMA and certain current and future DB QPAMs, to continue to rely upon relief provided by Prohibited Transaction Exemption 84-14 (the QPAM Class Exemption), for up to three years, beginning on April 18, 2021, notwithstanding the 2017 criminal conviction of DB Group Services (UK) Limited.
PTE 2021-02; D-12030
The Goldman Sachs Group, Inc. (Goldman Sachs)
Permits certain qualified professional asset managers that are within the corporate family of Goldman Sachs (the Goldman Sachs Affiliated QPAMs and the Goldman Sachs Related QPAMs), as defined in the exemption, to continue to rely upon relief provided by Prohibited Transaction Exemption 84-14 for a period of up to five years, notwithstanding the judgment of conviction against Goldman Sachs (Malaysia) Sdn. Bhd. (Goldman Sachs Malaysia), an indirect, wholly owned subsidiary of Goldman Sachs, for conspiracy to violate the anti-bribery provisions of the Foreign Corrupt Practices Act of 1977. This exemption is effective for a period of five years beginning on the date a judgment of conviction against Goldman Sachs Malaysia Sdn. Bhd., in Cr. No. 20-438 (MKB), is entered in the United States District Court for the Eastern District of New York.
PTE 2021-03; L-12000 & L-12001
Electrical Insurance Trustees Insurance Fund (the EIT Fund) and the Electrical Joint Apprenticeship and Training Trust (the EJAT Trust; together, the Plans)
Permits: (a) the sale by the EJAT Trust of 5.11 acres of unimproved real property (the Property) to the EIT Fund, a party in interest with respect to the EJAT Trust; and (b) the EIT Fund’s granting of a right of first offer to the EJAT Trust, for the purchase back of the Property by the EJAT Trust from the EIT Fund.
Mitsubishi UJF Trust and Banking Corporation (Mitsubishi)
If granted, this proposed exemption would permit Mitsubishi, a foreign banking corporation organized under the laws of Japan, and its affiliate, MUFG Alternative Fund Services (Cayman) Limited, (together referred to as, “MUTB”), to engage in certain transactions with employee benefit plans that are subject to ERISA and the Code, in connection with MUTB’s arrangement and syndication of revolving lines of credit to certain investment funds, which are secured by the capital commitments of the funds’ investors.