Overview

• The FTC and DOJ continue to accept HSR notifications, with waiting periods running as usual and filings after 5 p.m. ET treated as filed the next business day.
• The FTC’s Premerger Notification Office is operating 9 a.m. to 1 p.m. ET, will not grant early termination, and is not answering informal HSR questions, so parties must observe full waiting periods to avoid daily civil penalties.
• Contingency plans keep roughly 50% of the FTC Bureau of Competition and about 60% of DOJ Antitrust staff working, constraining capacity for substantive review.
• Parties should expect slower responsiveness and a higher likelihood of pull-and-refile requests or Second Requests that could reset timelines and delay closings.
• CFIUS has suspended active transaction reviews with deadlines tolled, and parties should not expect filings to be accepted for review during the funding lapse.