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Insights

advice for businesses in dealing with the expanding coronavirus events

HSR Filings Impacted by COVID-19

March 15, 2020

By Michael Wise

On Friday, March 13, 2020, the Premerger Notification Office of the Federal Trade Commission issued a press release detailing changes to the normal procedures for accepting and reviewing premerger notification filings under the Hart-Scott-Rodino Act (“HSR Act”). The announcement follows guidance from the Office of Personnel Management, that agencies should promote telework and social distancing to the extent possible to prevent the spread of COVID-19. These changes may affect timing for transactions currently under review and those that would necessitate HSR filings in the coming weeks.

  • HSR filings will not receive Early Termination for the foreseeable future.

  • Parties should be prepared for HSR filings to take longer than normal.