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Client Alert

March 16, 2020

FTC Announces Temporary Filing Procedures Due to Coronavirus


On Friday, March 13, 2020 the Federal Trade Commission and the Department of Justice Antitrust Division announced plans to implement temporary new procedures for the submission of Hart-Scott-Rodino pre-merger notification filings in response to the continued spread of the COVID-19 coronavirus. Beginning on Tuesday, March 17, 2020, both the FTC Premerger Notification Office and the DOJ will only accept HSR filings submitted using a secure file-transfer platform.1Guidance for Filing Parties, FTC (Mar. 13, 2020), available here. No filings will be accepted on Monday, March 16, 2020.2Id.

Although FTC and DOJ review of HSR filings will continue normally, the agencies will not grant early termination while these temporary procedures are in effect and parties may be required to submit hard copies of their HSR filings once normal agency operations resume.3Id.