Goldman Sachs Wins Five-Year Regulatory Get-Out-of-Jail Pass
Published Date: 6/4/2026
Notice
Summary
Starting June 9, 2026, and lasting five years, certain Goldman Sachs asset managers in New York can keep using a special exemption despite past legal issues. This helps retirement plans work smoothly with Goldman managers while making sure they follow important rules and act responsibly. If plans want to stop working with Goldman, they can do so without big costs or problems.
Analyzed Economic Effects
5 provisions identified: 5 benefits, 0 costs, 0 mixed.
Goldman must indemnify plans for actual losses
Goldman Affiliated QPAMs must indemnify and hold harmless a Covered Plan for any actual losses directly resulting from a QPAM's violation of the exemption conditions, ERISA fiduciary duties, or prohibited transaction rules. The term "actual losses" explicitly includes costs from unwinding transactions, transitioning plan assets to another manager, and exposure to excise taxes under Code section 4975.
Goldman managers may keep serving plans
From June 9, 2026 through June 8, 2031, certain current and future Goldman-affiliated asset managers can continue to rely on the QPAM class exemption (PTE 84-14) despite the GS Malaysia FCPA conviction, provided they meet the exemption's conditions. This is meant to prevent disruption to ERISA-covered plans and IRAs that use Goldman managers.
Plans can terminate Goldman without big costs
The exemption requires that Covered Plans be able to terminate or withdraw from arrangements with a Goldman Affiliated QPAM for separately managed accounts or pooled ERISA funds in an orderly and cost‑effective way. Goldman may not impose undisclosed or broad penalties for termination and may only charge reasonable, pre-disclosed fees tied to liquidity or valuation limits.
Strict compliance: training, policies, final audit
Each Goldman Affiliated QPAM must maintain written policies, provide annual training, and conduct an independent audit covering the final 12 months of the exemption period (ending June 8, 2031). The audit must be completed within 60 days after June 8, 2031, and the certified Audit Report must be submitted to the Department no later than 45 days after audit completion and made available to regulators and Covered Plans.
Goldman must notify plans about the conviction
Within 60 days of the exemption's effective date, each Goldman Affiliated QPAM must provide each Covered Plan sponsor and beneficial owner with a Federal Register copy of the exemption, a separate summary describing the facts that led to the GS Malaysia FCPA conviction, and a prominently displayed statement that the conviction results in a failure to meet a PTE 84-14 condition. New prospective Covered Plan clients must receive these materials prior to or when they receive an investment management agreement.
Personalized for You
How does this regulation affect your finances?
Personalize government policy and PRIA will tell you what this federal register document means for your household, plus every other regulation we track. PRIA reads each provision against your financial profile to show you exactly what matters to your wallet.
Key Dates
Department and Agencies
Related Federal Register Documents
2026-17622, Federal Independent Dispute Resolution Operations; Correction
This document corrects typographical errors and omissions in the final rule that appeared in the June 4, 2026, Federal Register titled "Federal Independent Dispute Resolution Operations" (referred to hereafter as the "IDR final rule"). The effective date of the IDR final rule was August 3, 2026.
2026-14917, Electronic Disclosure by Group Health Plans Under ERISA
Group health plans can soon share important info online instead of paper, making it easier and cheaper for everyone. If this rule passes, plan administrators must notify members about electronic disclosures but still offer paper copies if requested. This change affects anyone in group health plans under ERISA and aims to save time and money starting after the rule is finalized.
2026-11140, Federal Independent Dispute Resolution Operations
Starting soon, health plans and insurers must share clearer info when they pay or deny surprise medical bills. They’ll use special codes to explain these decisions, especially when dealing with folks they don’t have contracts with. This helps patients and providers understand bills better and speeds up fixing disputes, with no extra costs for most people.
2026-05492, Retirement Security Rule: Definition of an Investment Advice Fiduciary: Notice of Court Vacatur
The court has canceled the Department of Labor’s 2024 rule that changed who counts as a trusted investment advisor for retirement plans. Starting April 20, 2026, the old rules from 2020 will be back in charge, affecting financial advisors and retirement plan managers. This means advisors should review their practices to stay on the right side of the law and avoid costly mistakes.
2025-14281, Pooled Employer Plans: Big Plans for Small Businesses
Small businesses get a big boost with new guidance on pooled employer plans (PEPs), which help them offer better, cheaper retirement savings options. The government is asking for feedback to create clear rules that make joining these plans easier and more affordable. Starting soon, these changes aim to save workers money and help small employers attract great employees.
2026-17143, Exemption for Certain Prohibited Transactions Involving Liberty Puerto Rico 401(k) Savings Plan (the Plan or the Applicant) Located in San Juan, Puerto Rico
This exemption permits the Plan's prior acquisition, holding, and sale of certain stock rights (the Rights) to purchase shares of stock in Liberty Latin America Ltd. (LLA). Absent an exemption, these transactions would be prohibited by the Employee Retirement Income Security Act of 1974 (ERISA) and/or the Internal Revenue Code of 1986 (the Code).
Previous / Next Documents
Previous: 2026-11220, Request for Information on Family Friendly Transit
The Federal Transit Administration wants your ideas on making public transit safer, cleaner, easier to use, and more reliable for families. They’re asking transit agencies and the public to help create new ways to measure how family-friendly transit really is. Share your thoughts by August 3, 2026, so they can build better tools and improve transit for everyone, especially families.
Next: 2026-11223, Combined Notice of Filings #1
The Federal Energy Regulatory Commission got several new filings from energy companies about big changes like mergers, new solar projects, and updates to electricity rates. These changes could affect how energy is bought and sold, with public comments open until mid to late June 2026. If you’re involved in energy or just curious, now’s the time to check out these updates and have your say!