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 | 5 min read | 08.21.26
FTC Proposes Enforcement Policy Statement on Personalized Pricing: What Businesses Need to Know
On August 19, 2026, the Federal Trade Commission (FTC) announced a proposed Enforcement Policy Statement on personalized pricing — the practice of companies using consumers’ personal data to set individualized prices, discounts, coupons, or other incentives. The proposed statement, which is open for public comment for 30 days following publication in the Federal Register, marks a major step up in the FTC’s focus on data-driven pricing strategies and puts businesses across industries on notice that undisclosed or inadequately disclosed personalized pricing will not be tolerated. Importantly, while the proposed statement is not a binding legal requirement and does not create new legal obligations, it serves as an enforcement warning that the FTC is prepared to use its existing enforcement authority under Section 5 of the FTC Act (Section 5) and is also a potential harbinger of rulemaking. Businesses that engage in — or are considering — personalized pricing should carefully assess their disclosure practices and data collection procedures against the standards articulated in this statement.
Client Alert | 7 min read | 08.19.26
CMS’s Final Rule Bans Federal Medicaid Funding for Youth Gender-Affirming Care
Client Alert | 2 min read | 08.19.26
