Hart-Scott-Rodino Act (HSR)

The Federal Trade Commission (“FTC”) released a shutdown plan dated September 29, 2025, outlining how it will operate during this lapse in appropriations.

FTC Commissioners are presidential appointees and are excepted from furlough during the shutdown. According to the shutdown plan, furloughs will be issued on a rolling basis for the staff to properly address

The Federal Trade Commission (“FTC”) has announced a final rulemaking on a unanimous vote that will expand the reporting requirements for mergers and acquisitions under the Hart-Scott-Rodino Antitrust Improvements Act of 1976 (the “HSR Act”). The new reporting requirements will go into effect after the new year in mid-January 2025. No changes will be made

The U.S. Office of the Comptroller of Currency (OCC) released a notice of proposed rulemaking (NPR) seeking to “increase the transparency of the standards that apply to the agency’s review of business combinations involving national banks and Federal savings associations.” The NPR includes several amendments to the procedures for reviewing proposed bank mergers under the Bank Merger Act (BMA).