Overview

• The FTC and DOJ are accepting Hart-Scott-Rodino submissions with waiting periods continuing to run during the funding lapse.
• Early termination will not be granted, requiring parties to observe the full statutory period before closing.
• The Premerger Notification Office is online from 9 a.m. to 1 p.m. ET, treats submissions after 5 p.m. ET as filed the next business day, and will not answer HSR inquiries.
• Contingency plans keep essential staff working at reduced levels, including roughly 60% at DOJ Antitrust, 50% at the FTC Bureau of Competition, and 47% at the FTC Bureau of Economics.
• CFIUS has suspended transaction reviews with deadlines tolled, creating potential delays for foreign investment clearances and knock-on impacts to closing timelines and litigation schedules.