FTC Issues New HSR Form – What You Need To Know

For the first time in over 45 years, the Federal Trade Commission (FTC) adopted on October 10, 2024, extensive changes to the notification form for acquisitions subject to Hart-Scott-Rodino Act (HSR) review. The new form requires less information than the FTC's sweeping 2023 proposal. Nevertheless, it will fundamentally change the way in which transactions are reported in the United States and materially increase the burden of preparing HSR filings.

The FTC has also announced that when the new form becomes effective, it will restore availability of early termination of the 30-day initial HSR waiting period. This will truncate the waiting period for transactions that plainly do not raise antitrust concerns.