Eric Saga

Feb 26, 2024 | lexology.com | Robert Baldwin |Logan Breed |Ken Field |Michele Harrington |Ilana Kattan |Eric Saga

In late January 2024, the Federal Trade Commission (“FTC”) released an updated operating plan in the event Congress does not pass a funding bill and the government shuts down. In a dramatic departure from prior practice, the FTC for the first time plans to also close down its premerger filing operations during such a scenario. This change will prevent merging parties from making required Hart-Scott-Rodino (“HSR”) filings and starting required HSR pre-closing waiting periods during the shutdown.