Client Alerts & Newsletters

FTC Announces Resumption of Early Termination for HSR Filings


The Federal Trade Commission announced on Friday that it will return to processing requests for early termination for HSR filings following a suspension of such grants for the last two weeks.  On March 13, the FTC and DOJ announced the adoption of a temporary e-filing program for HSR filings as part of the agency’s response to the COVID-19 coronavirus pandemic and the agency’s shift to a remote working environment.  Among the changes implemented, the agencies announced they would suspend the processing of requests for early termination of the HSR Act’s waiting periods. 

Citing success with the temporary e-filing program, the Commission announced that effective Monday, March 30, both the FTC and DOJ will resume the practice of assessing and granting early termination where appropriate.  The agency warned, however, that early termination will only be granted as time and resources allow and there are likely to be fewer grants and those grants will likely happen later in the waiting period than they have historically. 

Clients should be advised that while this development increases the chances parties can truncate the HSR waiting period, they should continue to be cautious in relying on a likely grant of early termination until the COVID-19 situation is resolved. 

Click here to read a full the Commission’s announcement.

For more information, please contact the professional(s) listed below, or your regular Crowell & Moring contact.

Shawn R. Johnson
Partner – Washington, D.C.
Phone: +1 202.624.2624

Connor Ahearn
Associate – Washington, D.C.
Phone: +1 202.624.2724

Kate M. Watkins
Associate – Washington, D.C.
Phone: +1 202.624.2744

Crowell & Moring LLP is an international law firm with offices in the United States, Europe, MENA, and Asia that represents clients in litigation and arbitration, regulatory and policy, and transactional and corporate matters. The firm is internationally recognized for its representation of Fortune 500 companies in high-stakes litigation and government-facing matters, as well as its ongoing commitment to pro bono service and diversity, equity, and inclusion.

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