FTC Proposes HSR Changes: Would Require More Documents from All Filers, Extensive New Information from Private Equity Funds, Foreign Manufacturers, and Others

On August 16, the FTC published for public comment a series of proposed changes to the information required for a premerger notification filing under the HSR Act. The proposed changes would broaden the scope of documents submitted with the filing for all filers. They would also require extensive new information from non-U.S. manufacturing facilities and from investment private-equity funds. The public has until October 18, 2010 to comment on the proposed changes.

This Alert Memo summarizes the proposed changes and their potential impact on the burden of complying with the HSR process.