On June 29, 2023, the Federal Trade Commission published a Notice of Proposed Rulemaking that would dramatically expand HSR reporting requirements. The historic changes fundamentally alter the HSR reporting landscape, shifting to more of a “white paper” approach, similar to that of ex-U.S. jurisdictions like the EU. These modifications bring new expansive reporting requirements to nearly sixfold the number of transactions seen in the EU. The move would substantially increase the burden on reporting parties, and impact deal timing and certainty.

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