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Firm Memoranda

FTC Announces Final Changes to Premerger Notification Form

Date: 10/28/24

The FTC recently announced extensive final changes to the Premerger Notification and Report form. Although less burdensome than the initial June 2023 overhaul proposal, the changes still require filers to provide significantly more information and documents than the current Hart-Scott-Rodino Antitrust Improvement Act (HSR) framework. Filers will need to prepare for increased time and expense to ensure compliance.

This Final Rule is aimed at addressing information gaps and enhancing the detection of antitrust risks, considering the dramatic changes that have taken place with respect to markets, investment strategies, and corporate structures over the past 45 years. The Department of Justice also announced its concurrence with the Final Rule.

CGR Memo - FTC Announces Final Changes to Premerger Notification Form (pdf | 284.33 KB )