The Federal Trade Commission ("FTC") announced its
annual revision to the thresholds for premerger reporting of
proposed acquisitions to the United States antitrust authorities
under the Hart-Scott-Rodino Antitrust Improvements Act of 1976, as
amended (the "HSR Act").1 Effective February
23, 2022, the minimum size-of-transaction threshold will increase
to $101 million.2 The FTC and the U.S. Department of
Justice ("DOJ" and, together with the FTC, the
"agencies") have not yet reinstated their practice of
granting early termination of the 30-day waiting period under the
HSR Act.
The HSR Act thresholds are adjusted annually, based on the
change in gross national product, and unlike the lower thresholds
last year, this year the thresholds increased substantially. Under
the new thresholds, transactions that will result in one person
holding more than $101 million (originally $50 million) of another
person's assets, voting securities or non-corporate interests
may be
