As we reported on July 7, the Federal Trade Commission, with the concurrence of the U.S. Department of Justice, released a Notice of Proposed Rulemaking (NPRM) to overhaul the Hart-Scott-Rodino (HSR) Act of 1976’s premerger notification process. If adopted as a final rule, the proposed changes will be massive and will require filers to submit extensive additional information not currently required to be furnished as part of an HSR filing. As a result, filers will experience increased burden and expense. The NPRM is in the comment phase, which is the public’s only opportunity to provide feedback before the final rule is adopted. Recognizing that the volume of comments is likely to be significant, the agencies have extended the deadline for submission of comments from Aug. 28 to Sept. 27. This extension will likely impact when the final rule is effective. The final rule will take effect 60 days after it is published in the Federal Register. While it is still possible for a final rule to take effect in late 2023, we believe it is more realistic to expect that a final rule will be released in early to mid-2024.