FTC Temporarily Suspends Early Terminations

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The FTC and DOJ announced today the temporary suspension of the practice of granting “early termination” of the HSR waiting period. In other words, for the time being, you should assume that any reportable transaction will require the full 30-day waiting period (shorter in all-cash tender offers). This is expected to be a short-duration suspension. See FTC press release 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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