Coming Soon – Overhaul of the HSR Notification and Report Form
This Bulletin is brought to you by AHLA’s Antitrust Practice Group.
- January 13, 2025
- Jonathan Elsasser , Clifford Chance US LLP
- Lauren Rackow , Clifford Chance US LLP
- Brian Concklin , Clifford Chance US LLP
Beginning in early 2025, the U.S. antitrust authorities likely will implement significant changes to the Hart-Scott-Rodino Antitrust Improvements Act of 1976, as amended (HSR) Notification and Report Form (Form) that would require additional time and resources for parties to HSR-reportable transactions. On October 10, 2024, the Federal Trade Commission (FTC) and the Department of Justice (DOJ) finalized changes to the HSR Form that overhaul the information that must be included in these filings. The changes are set to take effect on February 10, 2025. Agency guidance published on January 2, 2025 reiterates February 10 as the effective date, but implementation still may be delayed due to the upcoming transition in presidential administrations.
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