FTC Unveils Sweeping Modifications To HSR Merger Notification Form

Key Takeaways

• On October 10, the FTC published new HSR forms, representing the first "significant" overhaul to the HSR forms in 45 years. The new HSR forms will become effective 90 days following the publication of the Final Rule in the Federal Register, which is likely to be published in the next two weeks.
• The new HSR forms require substantial additional information and documentation from filing parties.
• The new HSR forms do not alter current filing thresholds or filing fees.

The Federal Trade Commission's (FTC) Final Rule mandates the adoption of new, expanded Hart-Scott-Rodino (HSR) forms¹ and the creation of a public comment portal for pending transactions.² The new HSR forms will become effective 90 days after the Final Rule is published in the Federal Register. The new forms require much more information and documentation than the present forms. The new forms do not alter current filing thresholds or filing fees.³ Additionally, the