Federal Register #D-12122

Proposed Exemption for Goldman Sachs Asset Managers under PTE 84-14

This notice outlines a proposed regulatory exemption by the Department of Labor for Goldman Sachs asset managers: - Government Buyer: - Department of Labor, Employee Benefits Security Administration - OEMs and Vendors: - The Goldman Sachs Group, Inc. - Affiliated asset managers including: - Goldman Sachs Trust Company, N.A. - Goldman Sachs Bank USA - Goldman Sachs Asset Management, L.P. - Goldman Sachs Asset Management International - Goldman Sachs Asset Management Co., Ltd. - Goldman Sachs Asset Management (Singapore) Pte. Ltd. - Goldman Sachs Asset Management Australia Pty Ltd - Goldman Sachs Asset Management Canada - Goldman Sachs Asset Management Korea Co., Ltd. - Goldman Sachs Asset Management (Hong Kong) Limited - Goldman Sachs Asset Management (Japan) Limited - Goldman Sachs Asset Management (Asia) Limited - Products/Services Requested: - No products or services are being procured; this is a regulatory exemption affecting asset management operations - Unique or Notable Requirements: - Exemption allows Goldman-affiliated asset managers to rely on Prohibited Transaction Exemption 84-14 (PTE 84-14) despite a prior FCPA conviction - Imposes strict compliance, audit, and indemnification requirements on Goldman-affiliated QPAMs - Requires adherence to ERISA standards, independent audits, compliance reviews, and contractual protections for plan participants - Includes provisions to mitigate risks and costs if the exemption is lost - Period of Performance: - Exemption would be effective for five years - Place of Performance/Contracting Office: - Employee Benefits Security Administration, U.S. Department of Labor, Washington, DC

Description

This notice proposes an exemption allowing Goldman Sachs-related asset managers to rely on Prohibited Transaction Exemption 84-14 despite the GS Malaysia FCPA Conviction, provided certain conditions are met. The exemption aims to protect plans and their participants by imposing compliance, audit, and indemnification requirements on Goldman-affiliated qualified professional asset managers (QPAMs). The exemption would be effective from June 9, 2026, through June 8, 2031, and includes provisions to mitigate risks and costs associated with transitioning plan assets if the exemption is lost.

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