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ERISA Law Changes Daniel S. Shapiro ERISA Law Changes On August 17, President Bush signed into law the Pension Protection Act of 2006 1 ERISA Law Changes • Prior ERISA “Counting” Rules – Under former Plan Asset Regulations, a hedge fund was deemed to hold ERISA “plan assets” if 25% or more of value of any class of equity interest was held by “Benefit Plan” investors – “Benefit Plan” investors included non-US benefit plans and various US government plans. – If a hedge fund is a Plan Asset Fund – • Fund and Fund’s Manager subject to ERISA’s fiduciary rules • Fund subject to “prohibited transaction” provisions of ERISA ad US Internal Revenue Code. 2 Pension Protection Act (PPA) • The PPA Enacted the Following Changes with Respect to the Hedge Fund Industry – Foreign and government plan assets morphed from “bad” money into “good” money – Adopted proportionate counting – Changes greatly increase ERISA plan asset capacity of hedge funds – Some funds may want to restructure to maximize ERISA plan asset capacity 3 Proportional Counting: Old Law v. New Law Old Law: Clean Picture Feeder A Onshore LP $100 Feeder B Offshore Ltd. $100 No ERISA money No state plan money Feeder A is clean Class A < 25% BPI Class B < 25% BPI Feeder B is clean Master Fund is clean 4 Proportional Counting: Old Law v. New Law Old Law: ERISA Problems Feeder A Onshore LP $100 Feeder B Offshore Ltd. $100 Class A < 25% BPI Class B > 25% BPI (includes ERISA, foreign, state plans) Feeder B is 100% “bad” No ERISA money No state plan money Feeder A is clean Master Fund is subject to ERISA $100 $200 5 Proportional Counting: Old Law v. New Law New Law: Variation 1 Feeder A Onshore LP $100 Feeder B Offshore Ltd. $100 Class A has $10 and is 100% ERISA Class B has $90 and is 0% ERISA Feeder B is a BPI No ERISA money Feeder A is clean Master Fund is clean _$10_ $200 Assumes one class of shares 6 Proportional Counting: Old Law v. New Law New Law: Variation 2 Feeder A Onshore LP $100 Feeder B Offshore Ltd. $100 Class A has $10 and is 100% ERISA Class B has $90 of which $2 is ERISA No ERISA money Feeder A is clean Master Fund is clean _$12_ $200 Assumes one class of shares 7 Benefit Plan Investor Questionnaire 8 Avoiding Plan Assets • Prior Rules – Some managers created non-ERISA BPI vehicles – Side-by-sides / Master / Feeders – Integration issues 9 Avoiding Plan Assets: Old Law Non-ERISA BPI ERISA, Foundations Endowments, Foreigners No ERISA Master Offshore ERISA <25% ERISA <25% Domestic Fund Domestic No ERISA Offshore Non-ERISA BPI Fund Master 10 • These Vehicles are Unnecessary Under the New Rule – Should I restructure my fund? 11 Avoiding Plan Assets: New Law Potential Structure ERISA (<25%) Foundations, Endowments, Foreigners State and Foreign Plans Extra ERISA All ERISA ERISA <25% No ERISA Master Domestic Fund 12 • Questions – Should you keep/set up an ERISA-only feeder? – How much extra capacity can you build? 13