The Federal Trade Commission (“FTC”) and U.S. Department of Justice Antitrust Division (“DOJ”) have proposed to expand dramatically the scope and burden of preparing a merger filing in the United States. The proposed changes to the Hart-Scott-Rodino (“HSR”) Act rules and filing form would: (i) introduce obligations to address substantive antitrust issues in the HSR Form; (ii) require submission of data that could expand the scope of HSR investigations; and (iii) add significant administrative burdens in the form of information requests related to corporate organization, deal structure, financial disclosures, and day-to-day business operations. The proposed new filing form includes information requests designed to help DOJ and FTC identify and investigate issues consistent with their recently released draft merger guidelines.