FTC to Require Electronic HSR Filings due to Coronavirus

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Stinson - Corporate & Securities Law Blog

The FTC recently released the following information.  Due to the developing COVID-19 coronavirus pandemic, and consistent with guidance from the Office of Personnel Management, the Premerger Notification Office (PNO) will implement a temporary e-filing system. During this emergency, all filings must be submitted via this system, and all hard copy and DVD submissions will be suspended. Key facts are as follows:

  • The PNO will be open to accept hard copy and DVD Hart-Scott-Rodino filings until Friday March 13, 2020 at 5:00 p.m.
  • The PNO will not accept any filings on Monday, March 16, 2020.
  • Beginning at 8:30 am on Tuesday, March 17, 2020, the PNO will accept HSR filings only via the temporary e-filing system.
  • The system will involve uploading documents to a secure Accellion file-transfer platform using the same file formats as specified for DVD filings on the Style Sheet for Hart-Scott-Rodino Filings.
  • While this temporary system is in place, early termination will not be granted for any filing.
  • The Department of Justice will implement the same procedures.

You can find further information on the electronic filing procedures here.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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