Proposed Exemption for the Royal Bank of Canada and Its Current and Future Affiliates (Collectively, RBC or the Applicant) Located in Toronto, Ontario, Canada
Published Date: 1/17/2025
Notice
Summary
The Department of Labor is proposing a special exemption for the Royal Bank of Canada and its affiliates in Toronto, letting them keep using certain financial rules despite a 2024 court conviction related to tax fraud in France. This exemption would last from March 5, 2025, to March 4, 2030, giving RBC some breathing room to manage assets under these rules. People can send their thoughts or ask for a hearing by March 3, 2025.
Analyzed Economic Effects
3 provisions identified: 1 benefits, 2 costs, 0 mixed.
RBC QPAMs Allowed To Keep QPAM Relief
The Department proposes an exemption that would let certain Royal Bank of Canada affiliated investment managers (RBC QPAMs) continue to rely on the QPAM Exemption (PTE 84-14) despite the March 5, 2024 conviction of Royal Bank of Canada Trust Company (Bahamas) Limited. If granted, this relief would apply from March 5, 2025 through March 4, 2030 and would let covered ERISA plans and IRAs keep their current asset-management arrangements with RBC QPAMs during that period.
Millions In Potential Liquidation Costs
The application says that if RBC QPAMs lose QPAM status, plan clients could face significant liquidation and transaction costs. For example, RBC-managed ERISA fixed income portfolios total over $18.5 billion; specific examples include: Multi-Asset Credit ($400,000,000) with estimated liquidation costs of $1,400,000–$2,600,000 (35–65 basis points); Core Fixed Income ($1.5 billion) estimated $3,000,000–$3,750,000 (20–25 bps); and Emerging Markets Equity ($2.35 billion) estimated $11,280,000–$15,040,000 (48–64 bps).
Exemption Ends If Another Conviction Occurs
The proposed exemption would terminate immediately if RBC or an affiliate is convicted of a crime covered by section I(g) of PTE 84-14 (other than the March 5, 2024 conviction) during the March 5, 2025–March 4, 2030 Exemption Period. That means plans relying on the exemption could suddenly lose the ability to rely on PTE 84-14 if a new disqualifying conviction happens.
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