HSR Early Termination Procedures Suspending During Pandemic
Kelley Drye Client Advisory
March 16, 2020
Please be advised that the FTC and DOJ are suspending hard copy HSR filings effective today, and will be implementing an FTP site for electronic-only HSR filings shortly.  No filings at all will be accepted today.  The FTC notes the following with regard to their new system.  Note, in particular, that the agencies will not grant early termination for any filing so long as this system is in place.

  • 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.

More information on the specific procedures for filing, for the present time, is available here.