FTC Staff Provides Guidance on Hart-Scott-Rodino Procedures

The Premerger Notification Office staff of the Federal Trade Commission ("FTC") detailed the timeline for Hart-Scott-Rodino ("HSR") procedures.

In an FTC blog post, the staff explained that parties engaging in certain mergers and acquisitions must submit premerger notification filings and wait for a designated period of time before completing the transactions. The staff provided the following guidance related to HSR procedures:

• The waiting period begins when fully completed HSR filings from the buyer and seller are received by the FTC and the DOJ.

• For most transactions, the waiting period lasts 30 days.

• Parties can request early termination of the waiting period, which may be approved at the discretion of the FTC and the DOJ.

• If the DOJ or the FTC issues a "Second Request," then the parties must demonstrate substantial compliance with that request. A new 30-day waiting period will begin upon demonstration of substantial compliance.

• HSR filings generally are valid for one year after the date on which early termination is granted or the waiting period expires.