Overview
On Thursday February 4, 2021, the Federal Trade Commission and Justice Department announced the suspension of the practice of granting early terminations of merger reviews and a review of the processes and procedures for granting early terminations. The announcement cites "unprecedented volume" and "unprecedented times" as the reasons, however it also states that "[w]e anticipate that this temporary suspension will be brief." During this period, the agencies presume that they will need the full 30 days allowed under the Hart-Scott-Rodino Act to conduct their review (15 days in the case of a cash tender or bankruptcy transaction). The full press release is available here.
Steptoe regularly handles merger filings under the Hart-Scott-Rodino Act and provides antitrust compliance counseling to domestic and international clients across multiple industries.