1. Home
  2. |Insights
  3. |FTC Announces Resumption of Early Termination for HSR Filings

FTC Announces Resumption of Early Termination for HSR Filings

Client Alert | 1 min read | 03.30.20

The Federal Trade Commission announced on Friday that it will return to processing requests for early termination for HSR filings following a suspension of such grants for the last two weeks.  On March 13, the FTC and DOJ announced the adoption of a temporary e-filing program for HSR filings as part of the agency’s response to the COVID-19 coronavirus pandemic and the agency’s shift to a remote working environment.  Among the changes implemented, the agencies announced they would suspend the processing of requests for early termination of the HSR Act’s waiting periods. 

Citing success with the temporary e-filing program, the Commission announced that effective Monday, March 30, both the FTC and DOJ will resume the practice of assessing and granting early termination where appropriate.  The agency warned, however, that early termination will only be granted as time and resources allow and there are likely to be fewer grants and those grants will likely happen later in the waiting period than they have historically. 

Clients should be advised that while this development increases the chances parties can truncate the HSR waiting period, they should continue to be cautious in relying on a likely grant of early termination until the COVID-19 situation is resolved. 

Click here to read a full the Commission’s announcement.

Contacts

Insights

Client Alert | 3 min read | 05.28.26

PFAS Regulatory Alert: EPA Rolls Back RCRA Proposed Rule on “Hazardous Waste” but Does Not Disturb Proposed RCRA Rule on PFAS

Earlier this month, the U.S. Environmental Protection Agency (EPA) withdrew a February 2024 Biden administration proposed rule, “Definition of Hazardous Waste Applicable to Corrective Action for Releases From Solid Waste Management Units,” under the Resource Conservation and Recovery Act (RCRA).[1] The withdrawn proposal would have revised RCRA corrective action regulations to expressly apply the broader statutory definition of “hazardous waste,” rather than only the narrower regulatory definition. Now, EPA is maintaining the status quo for corrective action under RCRA. However, EPA’s withdrawal of its proposed RCRA hazardous waste definition makes no mention of its corresponding proposal from 2024 to list nine per- and polyfluoroalkyl substances (PFAS) as RCRA hazardous constituents.[2] This disjointed withdrawal, while providing some certainty for regulated entities, does not resolve how EPA plans to address PFAS under the RCRA program....

View All Insights