Overview

• The FTC and DOJ are continuing to accept Hart-Scott-Rodino filings, and statutory waiting periods are proceeding as normal.
• Early termination will not be granted during the shutdown, requiring parties to observe the full waiting period before closing.
• The Premerger Notification Office is operating on limited hours (9 am–1 pm ET) and will not answer inquiries or provide informal guidance.
• Lawyers, economists, and support staff needed for premerger work are excepted from furlough, and potential Second Requests could extend reviews, with premature closings risking civil penalties reported up to $53,088 per day.
• CFIUS has tolled review deadlines during the lapse, with filings accepted but unlikely to be acted on until operations resume.