Client Alert: FTC New Rule on HSR Form and Instructions to Take Effect Monday

On Monday, February 10, 2025, the Federal Trade Commission (“FTC”)’s new Rule concerning revisions to the Hart-Scott-Rodino (“HSR”) Premerger Notification Form and Instructions will officially take effect.

While the new HSR Rule pares back some aspects of the revisions initially outlined by the FTC in its 2023 Notice of Proposed Rulemaking, the Rule continues to represent a substantial departure from the prior Form and Instructions and imposes significant new burdens on all filers. For a detailed assessment of the Rule’s newly imposed burdens and obligations, please see our analysis published last fall.

The FTC has published the new form and instructions, which are available here.